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Federal Court Blocks CRA’s Bid to Obtain Six Years of Shopify Merchant Data

The ruling sets a precedent by limiting how tax agencies can request extensive data from third-party platforms.

Overview

  • Judge Guy Régimbald ruled the CRA’s demand for more than six years of Shopify records was overly broad and lacked a defined group of sellers.
  • The CRA sought detailed merchant information—including personal identifiers, bank details and transaction histories—under the Income Tax Act and Excise Tax Act.
  • Some of the same information had also been requested by the Australian Tax Office to verify compliance with Australian laws.
  • Shopify was awarded CAD 90,000 in legal costs after winning parallel cases over the data demand.
  • The CRA has 30 days to appeal the decision, underscoring tensions between tax enforcement and online seller privacy.