Whether or not a registrant is required to charge HST is largely determined by the Excise Tax Act, which is federal law. The Excise Tax Act includes a list of exemptions from HST for services that are provided by specific professionals.
As of June 20, 2024, psychotherapy/counselling therapy services rendered by psychotherapists and counselling therapists are exempt from the GST/HST. Even so, your accountant or a Canada Revenue Agency representative would be in the best position to provide guidance that is specific to your situation. See Schedule V, Part II of the Excise Tax Act.
Please visit these Government of Canada webpages for information on the exemption and detailed information on the GST/HST registration and deregistration requirements for those persons who make supplies of counselling therapy or psychotherapy services:
Exemption for Psychotherapy Services: https://www.canada.ca/en/revenue-agency/services/forms-publications/publications/notice334/proposed-amendment-exemption-psychotherapy-services.html
Exemption for Counselling Therapy Services: https://www.canada.ca/en/revenue-agency/services/forms-publications/publications/notice335/proposed-amendment-exemption-counselling-therapy-services.html
Q: What constitutes psychotherapy services for the purpose of the HST exemption? CRA has written that “[a] person who practises the profession of psychotherapy must refer to the governing body or relevant provincial legislation for the province in which they practise to determine whether the services they perform are psychotherapy services.”
A: In Ontario, CRPO defines psychotherapy as “the assessment and treatment of cognitive, emotional or behavioural disturbances by psychotherapeutic means, delivered through a therapeutic relationship based primarily on verbal or non-verbal communication.”
This includes providing psychotherapy to clients, and services closely related or ancillary to the scope, such as providing clinical supervision to enable client care and providing reports for clients relating to psychotherapy services. For additional information on what constitutes psychotherapy in Ontario, please consult CRPO’s Controlled Act resources [https://www.crpo.ca/controlled-act-of-psychotherapy/].
Please note CRPO cannot anticipate or adjudicate every possible situation. Registrants are advised to apply relevant rules and principles in consultation with their tax professionals.
It is important to note that, generally, to be exempt from GST/HST, assessments and reports provided by health care professionals must be made for the purpose of the protection, maintenance or restoration of the health of a person or for palliative care (with some noted exceptions). A full discussion is available in the GST/HST Policy Statement “Qualifying Health Care Supplies and the Application of the GST/HST to Supplies of Medical Examinations, Assessments, Reports and Certificates” and is available here:
Q: The CRA has indicated that the exemption only applies to services “rendered to an individual.” What about joint client situations (i.e., couple, family, or group therapy)?
A: CRPO’s position is that joint client situations involve treatment provided to individuals, as long as each person is receiving psychotherapy services.
Please note that the use of the word “individual” in CRA’s response mirrors the language of the legislation that supports the exemption. It is not intended to exclude couple, family or group therapy, where each individual is receiving psychotherapy. Couple, family and group psychotherapy are exempt from HST.
Are the services provided by a CRPO registrant eligible for a tax credit?
A Government of Canada website identifies that Registered Psychotherapists appear on the list of “Authorized medical practitioners for the purposes of the medical expense tax credit.” We also understand that “therapy plan” and “therapy” appear on the “List of common medical expenses” that are eligible for a tax credit. These services are only eligible for the tax credit when specific conditions are met – please visit the Government of Canada’s website or contact your tax advisor or accountant to explore how this information could impact your practice.