As Finance Canada contemplates ways to simplify the tax system, here are some early suggestions
Simplicity can be a double-edged sword in tax policy.
“A simpler tax system can help regular people pay their taxes accurately, collect their benefits and participate in the fiscal space with confidence. But simplification could also mean removing safeguards or mitigation measures that were put in place to ensure fairness and prevent fraud.”
Simplifying the tax code should not mean giving well-financed people or companies a roadmap to tax avoidance or aggressive tax planning at the expense of those who can’t afford professional expertise.
“The Canadian Tax Observatory is convinced that digital tools and clear thinking can make the tax system simpler for everyday taxpayers without having to compromise on policy objectives.” We at the Observatory have only scratched the surface in our research in this area but intend to do more.
For now, this document identifies five focused opportunities where unnecessary complexity may be reduced. The aim is a practical agenda for testing whether existing rules and delivery mechanisms achieve their objectives in the least burdensome way reasonably available.
A practical way of grouping paths to simplification could be:
| Type of work | Simplification opportunities |
| Administrative access | Disability Tax Credit; automatic filing and benefit access |
| Policy evaluation | Housing tax expenditures; targeted GST/HST relief |
| Structural review | GAAR and targeted anti-avoidance rules |
Here are five areas that are ripe for simplification. Each one connects with a larger complexity problem embedded in our tax system:
1. Disability Tax Credit
The DTC was designed as a tax equity measure to help offset the higher cost of living people with disabilities encounter. DTC certification has now become a gateway to more than a dozen other federal and provincial programs for people with disabilities. Applying for one program to get permission to then apply for other programs is complicated enough. But the certification process itself is also riddled with problems that stand in the way of many needy people with disabilities.
The Canadian Tax Observatory has done some groundwork on the problems and proposed some options to improve the system, including expanding eligibility criteria and the definition of disability, as well as streamlining administrative processes.
We are in the midst of doing further work in two separate areas: how to design technical improvements to the process in order to make certification easier for those in need; and modelling what a broader definition of disability could look like. We would welcome collaboration with the federal government, especially the Department of Finance, ESDC and CRA.
The issues with the DTC raise a bigger question related to simplification: at what point does using the tax system to deliver social programs become counterproductive?
Proposal
Reduce unnecessary barriers in the application and certification process while improving the consistency, accessibility and timeliness of decisions. The review should also examine whether DTC eligibility should continue to serve as the principal gateway to multiple disability-related programs.
What guides success
- Fewer incomplete applications and avoidable requests for additional information.
- Shorter and more predictable processing times.
- Lower burden for applicants and health practitioners.
- Fewer avoidable objections and reviews.
- Improved access among low-income applicants and other underserved groups.
- Greater consistency for applicants with comparable functional limitations.
2. Housing Affordability
With every passing election, each political party promises to solve the conundrum of costly housing, and they often turn to the tax system for tools. As a result, we now have multiple tax expenditures related to housing affordability, without much coherence or examination of how they inter-relate.
The Canadian Tax Observatory has done some initial research in this area. We zeroed in on the First Home Savings Account and found that the program, in practice, undermines its policy goals by favoring well-off home buyers of any age (or their parents) who could afford to buy a home regardless. We also pointed to the need for future research on other tax expenditures to look at unintended consequences.
For now, it’s unclear whether the mix of tax expenditures is actually improving affordability.
The issues we found with the FHSA raise a bigger question related to simplification: does the ever-growing list of tax expenditures match policy goals in an efficient way?
Proposal
Assess federal housing tax measures as a portfolio rather than as isolated incentives. Each measure should have a clear objective, an identifiable beneficiary and evidence that it improves affordability, access or supply at a reasonable fiscal and administrative cost.
What guides success
- Clearer alignment between each measure and its stated objective.
- Fewer measures that overlap or do not align/ build on each other.
- Greater transparency about beneficiaries, distributional effects and fiscal cost.
- Credible evidence of improved access or additional housing supply.
- Less support for transactions or savings that would have occurred without the measure (free rider).
3. Anti-Avoidance Rules
The General Anti-Avoidance Rule is meant to complement targeted anti-avoidance rules in order to uphold the integrity of the Canadian tax system and stifle tax avoidance. However, there is a growing number of specific anti-avoidance regimes that are meant to solve specific problems but that are not necessarily aligned with each other or with the GAAR.
As one expert told us, “We’ve effectively created overlapping safety nets with no clear hierarchy, which drives complexity, cost and uncertainty – and doesn’t necessarily produce better policy outcomes.”
We recognize that federal budgets in 2024 and 2025 included changes to the GAAR regime. Now, in 2026, it’s worth looking at what effects those changes have had on overlap, duplication and the ability for those with deep pockets to lawyer up and navigate the system.
Clarity, transparency and predictability can make for improved compliance. Here’s some further exploration on that subject from the Canadian Tax Observatory.
Proposal
Improve clarity and predictability in the relationship between the General Anti-Avoidance Rule and targeted anti-avoidance provisions, while preserving effective protection of the tax base. Complexity should be retained only where it serves a clear integrity purpose.
What guides success
- Clearer guidance on when the GAAR and targeted rules apply.
- Fewer duplicative or inconsistent provisions and legal tests.
- Reduced recurring uncertainty, compliance cost and need for costly rulings or litigation.
- More consistent administrative and judicial outcomes.
4. GST Breaks
History shows that when the government narrowly targets HST/GST cuts to specific products (the tampon tax, holiday spending, etc), businesses often keep the windfall and also have to grapple with an additional burden of compliance. The tax revenue is foregone, complexity increased and the benefit to consumers is usually not achieved.
The GST system is riddled with exemptions and exclusions, some of which make sense but others that have become outdated.
Narrowly targeted tax measures can be efficient and effective if they’re simple to administer and easy to understand. But they can backfire if the administrative burden is too high or if the windfall doesn’t go to consumers.
Proposal
Use narrowly targeted GST/HST relief only where it provides a clear advantage over direct assistance, refundable credits or broader relief. Product-specific measures should be evaluated for consumer benefit, distributional impact, fiscal cost, compliance burden and classification problems.
What guides success
- A high proportion of the tax reduction reaches consumers.
- The intended households receive a meaningful share of the benefit.
- Low implementation and ongoing compliance costs for businesses and government.
- Few product-classification disputes and boundary problems.
- Clear rules that can be implemented quickly and consistently.
- Demonstrated advantages over simpler alternative forms of assistance.
5. Automatic filing
We were glad to see some progress on automatic tax filing in the 2025 budget. However, complexity still stands in the way of many low-income people who are missing out on benefits because they don’t have their notice of assessment. With better user-oriented design, tax filing could become far more automatic, benefiting in particular those citizens who need every iota of help.
Proposal
Reduce the loss of income-tested benefits caused by non-filing and make filing substantially more automatic for people with simple tax situations whose income information is already largely held by government. The objective should be reliable benefit access, not merely completion of a tax return.
What guides success
- More eligible people receive the benefits and credits for which they qualify.
- Fewer people remain persistent non-filers because of procedural or access barriers.
- Low error, correction and reassessment rates.
- Reduced taxpayer burden and administrative cost.
- High completion and confirmation rates among the intended population.
Related reading
The Disability Tax Credit: where the access chain falls apart
This report summarizes the data and evidence collected as of July 2026, on the Disability Tax Credit with a focus on the administrative burdens for applicants.
October 7, 2026
Broken Links
Only 16 per cent of people with disabilities qualify for the Disability Tax Credit and the access that certification brings to other, crucial programs. New research from Dr. Gillian Petit identifies four different links in the system that a person with a disability must steer through to access proper income security and support.
April 22, 2026
April 22, 2026Researchdisability,poverty,disability tax credit
Broken Links II: Pinpointing Barriers. Improving Access. Reducing Poverty.
Broken Links II brings together two new reports on the Disability Tax Credit. The first maps 10 barriers that stop people from completing their application; the second models how automatic eligibility could lift up to 53,000 people out of poverty.
October 7, 2026
October 7, 2026Researchdisability,poverty,disability tax credit
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