In the past year, several clients have turned to us for assistance in filing their Underused Housing Tax (UHT) returns only after the statutory deadline had already passed. In these cases, the delay mostly resulted from a misunderstanding—either of the tax’s scope or the assumption that no filing was required if no tax was ultimately owed.
Experience now confirms: even where no tax is payable, a late return can lead to penalties—per year and per individual owner.
We are aware of cases in which
• CAD 1,000 per year,
• per owner,
• plus interest on the penalty
was assessed solely due to the late submission. In situations involving jointly owned property—such as between spouses—penalties were applied to each individual owner, effectively doubling the amount, even where only one house was involved.
The obligation to file remains—even if no tax is due.
Introduced in 2022, the UHT applies to certain Canadian residential properties that are not continuously used by their non-resident owners. Even if an exemption applies (e.g. because a property is seasonally inaccessible), a timely “nil” filing is still required.
The filing deadline for the 2024 calendar year is April 30, 2025.
If filings for prior years were missed, we strongly recommend addressing them as soon as possible. A voluntary disclosure may help mitigate penalties, although any decision remains at the CRA’s discretion.
If you own residential property in Canada and are unsure about your filing obligations, we can advise you.
