How long does the CRA have to collect my client's tax debt, and what restarts the clock?
As of October 2026, the CRA collection limitation period for income tax and GST/HST debts is 10 years under ITA s.222 and ETA s.313. For income tax it starts 90 days after the last notice of assessment. A payment, a written acknowledgment or a CRA collection action restarts the full 10 years, while a bankruptcy or proposal pauses it.
How long the CRA has to collect, by type of debt
The CRA's own table gives each debt type a 6 or 10 year collection limitation period, and the start day depends on the debt canada.ca.
| Debt | Clock starts | Period |
|---|---|---|
| Individual and corporate income tax | 90 days after the notice of assessment or reassessment is sent (the CRA calls it the 91st day) | 10 years |
| COVID subsidies for businesses | 90 days after the notice is sent | 10 years |
| GST/HST | When the notice of assessment or reassessment is sent | 10 years |
| Payroll debt | The day after the notice of assessment or reassessment is sent | 6 years |
| Employment insurance overpayment | The day the overpayment occurs | 6 years |
| COVID benefits for individuals | The date of the decision or notice of redetermination | 6 years |
| Customs debt | 90 days after the notice is sent | 6 years |
| Canada Student Loans and Canada Apprentice Loans | When the loan takes effect | 6 years (none for loans set up or expired before August 1, 2003) |
| Canada Pension Plan and Old Age Security debts | Not applicable | No limit |
For income tax the rule is ITA s.222(4): the period begins on the day that is 90 days after the last notice of assessment, or the last notice under s.226(1), is sent, and ends 10 years later, subject to the extensions in s.222(8) laws-lois.justice.gc.ca. The 90 days line up with the normal collection restriction in s.225.1, which blocks most collection steps until 90 days after the notice is sent
laws-lois.justice.gc.ca.
GST/HST runs under its own section. ETA s.313 starts the 10 years on the day the last notice of assessment (or notice under s.322(1)) is sent, with no 90 day gap laws-lois.justice.gc.ca.
What restarts the 10 years
A restart gives the CRA a full new 10 years from the restart day, as long as the event happens before the period would otherwise end. Under s.222(5), three things restart it: your client acknowledges the debt, the CRA commences an action to collect it, or the CRA assesses another person for it under s.159(3), s.160(2) or s.227(10)(a) laws-lois.justice.gc.ca.
Section 222(6) defines acknowledgment narrowly. It's a written promise to pay, a written acknowledgment of the debt (even one that refuses to pay), or a payment on the debt, including a cheque that later bounces. An acknowledgment by your client's agent or legal representative counts as your client's own under s.222(7) laws-lois.justice.gc.ca.
"Action" is broad. It includes court proceedings and anything the Minister does under s.164(2), the power to apply a refund to another debt and notify the taxpayer laws-lois.justice.gc.ca. So a refund or credit kept against the debt restarts the clock even if your client did nothing.
The CRA's list of restart events in practice canada.ca:
| Your client does | The CRA does |
|---|---|
| Makes a voluntary payment | Garnishes or sets off after voluntary payments stop |
| Writes to propose a payment arrangement | Applies a tax refund or other credit to the debt |
| Gives a written acknowledgment of the debt | Assesses a third party for amounts your client owes |
| Offers security instead of paying | Certifies the debt in the Federal Court |
| Makes a written request for reassessment | Starts seizure and sale of assets |
| Files a notice of objection or an appeal | |
| Asks about paying by preauthorized debit |
The CRA lists filing an objection or appeal as a restart event. The text of s.222(5) and (6) doesn't name an objection; the Act treats the time collection is barred during an objection as an extension under s.222(8)(a) laws-lois.justice.gc.ca. If a file turns on that point, read the section, not the CRA summary. Deadlines for objecting are on the notice of objection page.
What pauses the clock without restarting it
An extension adds days to the end date instead of starting over, so the total can run past 10 years. Under s.222(8), the end date moves out by every day on which laws-lois.justice.gc.ca:
| Pause | What it covers |
|---|---|
| s.222(8)(a) | Collection is barred under s.225.1(2) to (5): objection pending, Tax Court appeal pending, a referred question, or a written agreement to wait for a related case |
| s.222(8)(b) | The CRA holds security instead of payment |
| s.222(8)(c) | Your client was resident in Canada when the period began and is now a nonresident |
| s.222(8)(d) | Collection is restricted under the Bankruptcy and Insolvency Act, the Companies' Creditors Arrangement Act or the Farm Debt Mediation Act |
The CRA says the period pauses when it's notified that the event has started and resumes where it left off once the event ends canada.ca.
The objection pause only helps debts that are subject to collection restrictions. Section 225.1(6) switches those restrictions off for amounts that were required to be deducted, withheld and remitted (source deductions), s.116 amounts and Part VIII amounts, plus related penalties and interest laws-lois.justice.gc.ca. Objecting to a payroll assessment doesn't stop collection, so it doesn't extend the period either. Directors facing those amounts personally are covered on the director liability page.
Large corporations (taxable capital over $10 million) get only half the protection: the CRA can collect one half of the assessed amount 90 days after the notice even while an objection is pending, under s.225.1(7) laws-lois.justice.gc.ca.
Worked example: is a 2014 debt still collectible?
Your client's 2014 T1 was assessed with a balance owing, and the notice of assessment was sent on May 20, 2015. No reassessment followed. Here's the date math.
| Event | Date | Effect |
|---|---|---|
| Notice of assessment sent | May 20, 2015 | Clock not started yet |
| Period begins (90 days later) | August 18, 2015 | 10 years run from here |
| Original end date | August 18, 2025 | Expired, unless something intervened |
| CRA applies a GST/HST credit to the debt | May 3, 2021 | Restart: new end date May 3, 2031 |
| Consumer proposal stays collection for 240 days | Within the restarted period | Pause: end date moves 240 days |
| Final end date | December 29, 2031 | The CRA can collect until then |
Without the set off in 2021, the debt would have aged out on August 18, 2025. The single credit the CRA kept restarted 10 full years, and the proposal added 240 days on top. Before you tell a client an old debt has expired, get the full account history from the CRA and look for any payment, letter, refund offset or third party assessment inside the period canada.ca.
What happens once the period ends
Section 222(3) bars the CRA from commencing any action to collect the debt after the limitation period ends laws-lois.justice.gc.ca. The CRA says the debt still exists, though: it just usually can't take further collection action
canada.ca.
Your client can still pay voluntarily, and the CRA says that payment shouldn't restart the period canada.ca. That matches the Act, because a s.222(5) restart only works if the event happens before the period would otherwise end
laws-lois.justice.gc.ca.
Two exceptions, per the CRA: a voluntary payment on a Canada Student Loan or Canada Apprentice Loan, and an acknowledgment of a COVID benefit debt for individuals, can restart the period after it ends. For an expired EI debt, the CRA's advice is to make no payments at all canada.ca.
Sources
Does setting up a payment arrangement restart the 10 years?
Yes. Writing to propose a payment arrangement restarts the period, and so does each voluntary payment your client makes under it canada.ca. For a client who will pay in full, that doesn't matter. For one hoping an old balance expires, it does. How arrangements work is on the payment arrangement page.
Does a section 160 assessment against my client's spouse restart the clock on my client's debt?
Yes. Assessing another person for the debt under s.160(2), s.159(3) or s.227(10)(a) restarts the period under s.222(5)(c), as long as the assessment comes before the period ends laws-lois.justice.gc.ca.
Can the CRA keep my client's refund to pay a debt whose period has ended?
Not under the Act. Applying a refund to another debt under s.164(2) is an "action" in s.222(1), and s.222(3) bars commencing an action after the limitation period ends laws-lois.justice.gc.ca. If you see a refund applied to an expired debt, ask the CRA to show what restarted or extended it.
Is the collection period the same as the reassessment period?
No. The collection period limits how long the CRA can collect a debt that has already been assessed, while the reassessment period limits how long it can change the assessment itself. A reassessment issues a new notice, and the 10 years for income tax start again 90 days after that last notice laws-lois.justice.gc.ca. See the reassessment period page for those limits.
General information for the tax year shown, not advice for a specific client. Confirm the facts before you file or remit.