Voluntary Disclosures
The Canada Revenue Agency’s (CRA) Voluntary Disclosures Program (VDP) allows taxpayers to correct prior tax errors or omissions and, where eligibility requirements are met, to obtain relief from penalties and interest.
Since October 1, 2025, the federal VDP generally provides two levels of relief. Unsolicited applications, namely disclosures made before any CRA contact regarding a compliance matter, may qualify for relief of 100% of applicable penalties and 75% of applicable interest. Solicited applications, submitted following CRA communication regarding a compliance issue, may qualify for relief of up to 100% of applicable penalties and 25% of applicable interest. Where an application is accepted, protection from criminal prosecution is also available.
Revenu Québec also administers a voluntary disclosure program that, in eligible cases, may allow taxpayers to avoid penalties and penal proceedings and obtain certain interest relief.
In an environment of heightened compliance obligations and increased tax scrutiny, a well-prepared and thoroughly documented disclosure is essential to regularizing a tax situation in an orderly and credible manner.
How We Help
- Assessment of the situation and preliminary evaluation of eligibility under the federal VDP and the applicable Quebec program
- Preparation and submission of complete, rigorous, and well-documented disclosure files
- Coordination with federal and provincial tax authorities to ensure a coherent and structured approach
- Follow-up on the disclosure process and response to requests for additional information
- Support aimed at restoring and maintaining future tax compliance.
Our Approach
We provide personalized support at every stage of the process, with the goal of achieving a secure and compliant regularization of your tax situation under the best possible conditions.
Frequently Asked Questions
Common questions about Canadian and international taxation
For informational purposes only. See disclaimer.
The CRA's Voluntary Disclosures Program (VDP) allows a taxpayer to correct past errors or omissions in tax matters administered by the CRA. If relief is granted, the taxpayer must still pay the tax owing, but may receive relief from certain penalties and a portion of the interest, and may also obtain protection from criminal prosecution in respect of the disclosed matters.
To be eligible, the application must generally:
- be voluntary;
- relate to at least one tax year whose filing due date is at least one year past;
- involve an error or omission giving rise to interest, penalties, or both;
- include all relevant information and supporting documentation; and
- include payment of the estimated tax owing, or a request for a payment arrangement, if applicable.
The taxpayer must disclose all known errors and omissions. Generally, supporting documentation must be provided for the six most recent years, and if the errors or omissions relate to assets or income located outside Canada, the period is generally extended to ten years. The CRA may also request additional years where appropriate.
Since October 1, 2025, the CRA distinguishes between unprompted and prompted applications. As a general rule:
- an unprompted application is normally eligible for 75% relief on applicable interest and 100% relief on applicable penalties;
- a prompted application is normally eligible for 25% relief on applicable interest and up to 100% relief on applicable penalties.
An application will generally not be considered voluntary if an audit or investigation has already been initiated against the taxpayer or a related taxpayer in respect of the disclosed information.
Certain applications are generally not eligible, including those seeking only a refund, those with no tax or penalty exposure, those seeking relief from penalties or interest already assessed, certain applications relating to tax elections, matters involving an insolvency event, matters covered by an advance pricing arrangement, and matters depending on competent authority discretion under a tax treaty.
Québec also administers a separate voluntary disclosure program through Revenu Québec for provincial tax obligations. Minato Tax Solutions Inc. helps clients assess eligibility under the VDP, prepare complete disclosures, and manage the process to bring their tax affairs into compliance.
Have a tax situation to work through?
Book a consultation with Akira Kamio, CPA auditor, LL.M. (Taxation), specialist in Canadian and international income tax.