--- oa_review_kit: v1 guide_slug: mb-rst guide_version: mb-rst@2026-05-27T06:34:43.918Z archetype: other --- # Review kit: MB Rst Thank you for reviewing this Guide. This kit is one file with three parts: how to use it, an interview prompt for your AI, and the Guide itself. ## How to use this kit (3 steps, about 15 minutes) 1. Open the AI you already use (ChatGPT, Claude, Gemini, anything that reads markdown) and paste in everything from "INTERVIEW PROMPT" below, including the Guide at the end. 2. Your AI interviews you like a colleague, one question at a time. Just talk: war stories, walk-throughs, the mistakes you catch. No writing required. 3. Your AI writes your answers up as a single markdown file. Hand it back at openaccountants.com/skills/mb-rst/handback (also linked from the Guide page: "Hand back your file"). What you added is published under your name and credential. If your AI cannot produce the exact output format, hand back whatever you have: a revised Guide file, a worksheet, or plain notes. We take those too, and a person reviews them by hand. The format below is the one we can apply straight away. --- # INTERVIEW PROMPT (paste from here down into your AI) You are interviewing a practising accountant about how they actually do the work covered by the attached Guide ("MB Rst", slug `mb-rst`). Interview them like a colleague doing a handover. Do not lecture. Ask ONE question at a time and wait for the answer. Chase war stories and specifics: what kind of client, which portal step, how big the penalty was. The rates, thresholds, and citations are our job; we refresh those from primary sources. Capture ONLY what is NOT derivable from law: - order of operations, and what a wrong order corrupts - what to ask a client before computing anything - what to assume when a fact is unknown, and how it gets flagged - the most-missed traps, with penalty size and who falls in - how the portal or filing channel actually behaves - what has to reconcile before anyone signs - when to refuse the work and hand it to a human specialist If the accountant corrects a rate, threshold, or deadline in the Guide along the way, record it in the FACT CORRECTIONS table, but do not steer the interview toward numbers. ## Questions to work through Ask these in order, one at a time. Skip any the accountant has already covered; follow up where a story has specifics worth pinning down. Each question is tagged with the method slot(s) it feeds. 1. [sequence] Walk me through the last one of these you did for a real client, start to finish. What did you open first, and why that order? 2. [intake_questions] A new client sits down for this work. What are your first five questions before you touch a number? 3. [evidence] Which documents do you insist on seeing, and which do you take the client's word for? 4. [trap] When you review this work drafted by someone else, what mistake do you catch most often? 5. [conservative_default] When a key fact is unknowable at draft time, what do you assume, and how do you flag it? 6. [judgment_rule] When the law allows two routes, how do you actually pick, and what do you write down about the choice? 7. [cross_check] Before you sign, what has to reconcile with what, and how close is close enough? 8. [filing_mechanics] Walk me through the actual submission: the portal steps, the order things must happen in, what locks, what you can't undo. 9. [scope_gate] Which clients do you refuse or refer to a specialist for this work? What makes you stop? 10. [unsettled_law] Anything here you deliberately won't finalise right now because the rules are moving? 11. [handback_protocol] What exactly do you hand over at the end? What's in your working paper? ## Method slots (for tagging the write-up) - `scope_gate` (Scope gate and refusals): when to stop and send the client to a human - `sequence` (Order of operations): what order to do things in, and what a wrong order corrupts - `intake_questions` (Client intake questions): what to ask a client before computing - `evidence` (Documents and evidence): which documents to insist on, and what is draft-grade vs file-grade - `judgment_rule` (Judgment rules): how a practitioner actually picks when the law allows two routes - `conservative_default` (Conservative defaults): what to assume when a fact is unknowable at draft time - `trap` (Traps and most-missed items): the mistakes everyone makes, what they cost, and who falls in - `filing_mechanics` (Portal and filing mechanics): how submission actually works: channel, order, what locks - `cross_check` (Cross-checks before signing): what has to reconcile with what before delivery, and how close is close enough - `pattern_library` (Pattern library): how messy real-world data (bank lines, payout platforms) maps to tax categories - `edge_case` (Edge-case playbook): the client situations that change the method, not just the numbers - `unsettled_law` (Unsettled-law flags): what not to finalise right now, and why - `handback_protocol` (Hand-back protocol): what the finished working paper contains and who reviews it ## Output format: oa-handback v1 When the interview is done, write the answers up as ONE markdown file in exactly this shape. Fill in the reviewer's real name, credential, and email (ask for them at the end if they have not come up). Every method block gets a `### [method:]` heading where `` is one of the 13 slot ids above. Keep `guide_slug` and `guide_version` exactly as given. Omit any section the interview produced nothing for, but keep the headings that remain exactly as shown. The `fact_key` column may be left blank when unknown. ```markdown --- oa_handback: v1 guide_slug: mb-rst guide_version: mb-rst@2026-05-27T06:34:43.918Z reviewer_name: reviewer_credential: # free text: CPA, EA, ACCA, Steuerberater... reviewer_email: verdict: --- ## METHOD ### [method:filing_mechanics] ### [method:intake_questions] - - ... ## FACT CORRECTIONS | fact_key | current | correct | source | |---|---|---|---| | | | | | ## FLAGS - [unsettled] - [refer] ## NOTES ``` If for any reason you cannot produce this exact format, output the accountant's corrections and methods as clear plain notes instead. The hand-back page accepts plain notes and revised Guide files too; this format is an optimization, never a gate. --- # THE GUIDE UNDER REVIEW --- name: mb-rst description: Use this skill for Manitoba Retail Sales Tax (RST) — 7% sales tax (NOT harmonized with federal GST). Triggers "Manitoba RST", "Manitoba PST 7%", "MB sales tax", "TAXcess Manitoba", "Manitoba sales tax online sales". jurisdiction: CA domain: international tax_year: 2025 --- # mb-rst ## Manitoba — Retail Sales Tax (RST) — Skill v1.0 ## 1. Quick reference **Quick reference table** | Item | Value | | --- | --- | | Standard RST rate | **7%** | | Tax base | Tangible personal property + specified taxable services | | Federal harmonization | **No** — RST is a separate provincial tax, stacked on top of 5% federal GST | | Effective combined rate (GST + RST) | **12%** on most taxable goods/services in MB | | Economic nexus threshold (non-resident sellers) | **CAD $10,000** in MB taxable sales in a 12-month period | | Portal | **TAXcess** (Manitoba Finance online services) | | Filing frequency | Monthly / Quarterly / Annually — assigned by Taxation Division based on volume | | Governing statute | The Retail Sales Tax Act (C.C.S.M. c. R130) | | Regulator | Manitoba Finance — Taxation Division | RST is administered provincially. It is NOT a value-added tax — there is no input tax credit (ITC) mechanism. Tax paid on inputs is generally a sunk cost unless a specific resale or production-input exemption applies. ## 2. Required inputs + refusal catalogue ### Required inputs before producing a return - **Required inputs list** — 1. **RST Number** (7-digit account number issued by Manitoba Finance). 2. **Filing period** (start and end date) and assigned filing frequency. 3. **Gross sales in Manitoba** for the period, split between: Taxable sales (TPP + taxable services delivered to MB customers); Exempt / zero-rated sales (groceries, prescriptions, residential rent, children's clothing, etc.); Sales to other provinces / export (out-of-scope for MB RST). 4. **RST collected** from MB customers during the period. 5. **Taxable purchases on which RST was not paid at source** (self-assessed RST on imports / out-of-province purchases used in MB). 6. **Accommodation revenue** separately, because the 5% lodging tax is reported in its own field. 7. **Commission entitlement** — vendors who file and remit on time may claim a small collection commission (capped); confirm whether the client is electing it. ### Refusal catalogue (out of scope for v1.0) **Refusal catalogue table** | Code | Refusal | Reason | | --- | --- | --- | | R-MB-1 | Insurance premium RST (auto, group life, property) | Specialized RST rules under the Act and bulletins; route to insurance specialist. | | R-MB-2 | Tobacco, fuel, cannabis, liquor taxes | Separate Manitoba tax statutes (Tobacco Tax Act, Fuel Tax Act, Liquor Gaming and Cannabis Control Act). | | R-MB-3 | Mining, oil & gas, electricity production input exemptions | Sector-specific certificates and bulletins; specialist review required. | | R-MB-4 | Real property contracts (RPCs) and the contractor / installer rules | Contractor pays RST on materials; intricate self-assessment regime — refer to Bulletin 005. | | R-MB-5 | Used vehicle and aircraft transfers between private parties | Valuation rules (Red Book / appraisal) and Autopac collection mechanics out of scope. | | R-MB-6 | Bundled / mixed supplies where >10% of value is a taxable service inside an otherwise exempt supply | Apportionment requires fact-specific analysis. | | R-MB-7 | First Nations on-reserve sales claiming s. 87 Indian Act exemption | Documentation and delivery-to-reserve evidence required; refer to Bulletin 047. | | R-MB-8 | Voluntary disclosure / arrears / audit defense filings | Requires direct negotiation with Taxation Division. | - **R-MB-1** — Insurance premium RST (auto, group life, property) _(Specialized RST rules under the Act and bulletins; route to insurance specialist.)_ - **R-MB-2** — Tobacco, fuel, cannabis, liquor taxes _(Separate Manitoba tax statutes (Tobacco Tax Act, Fuel Tax Act, Liquor Gaming and Cannabis Control Act).)_ - **R-MB-3** — Mining, oil & gas, electricity production input exemptions _(Sector-specific certificates and bulletins; specialist review required.)_ - **R-MB-4** — Real property contracts (RPCs) and the contractor / installer rules _(Contractor pays RST on materials; intricate self-assessment regime — refer to Bulletin 005.)_ - **R-MB-5** — Used vehicle and aircraft transfers between private parties _(Valuation rules (Red Book / appraisal) and Autopac collection mechanics out of scope.)_ - **R-MB-6** — Bundled / mixed supplies where >10% of value is a taxable service inside an otherwise exempt supply _(Apportionment requires fact-specific analysis.)_ - **R-MB-7** — First Nations on-reserve sales claiming s. 87 Indian Act exemption _(Documentation and delivery-to-reserve evidence required; refer to Bulletin 047.)_ - **R-MB-8** — Voluntary disclosure / arrears / audit defense filings _(Requires direct negotiation with Taxation Division.)_ - **Escalation rule** — If any of the above is present, stop and route to a credentialed Manitoba tax practitioner. ## 3. Rate structure **Rate structure table** | Supply | Rate | Notes | | --- | --- | --- | | Standard taxable supplies (TPP + taxable services) | **7%** | Applied to the selling price exclusive of GST. | | Liquor (retail) | 7% RST | Stacked with the federal excise + liquor markup. | | Tobacco | Tobacco Tax (specific per-unit) | RST does NOT apply on top — Tobacco Tax Act governs. **Refusal R-MB-2**. | | Fuel | Fuel Tax (specific per-litre) | Separate Act. **Refusal R-MB-2**. | | Accommodations (hotels, short-term rentals) | **7% RST + 5% Lodging Tax** = 12% provincial layer | Lodging tax reported separately on the RST return. | | Insurance premiums (taxable lines) | 7% | **Refusal R-MB-1**. | | Electricity / natural gas (residential) | Exempt | Commercial use generally taxable. | - **Standard taxable supplies (TPP + taxable services)** — **7%** _(Applied to the selling price exclusive of GST.)_ - **Liquor (retail)** — 7% RST _(Stacked with the federal excise + liquor markup.)_ - **Tobacco** — Tobacco Tax (specific per-unit) _(RST does NOT apply on top — Tobacco Tax Act governs. **Refusal R-MB-2**.)_ - **Fuel** — Fuel Tax (specific per-litre) _(Separate Act. **Refusal R-MB-2**.)_ - **Accommodations (hotels, short-term rentals)** — **7% RST + 5% Lodging Tax** = 12% provincial layer _(Lodging tax reported separately on the RST return.)_ - **Insurance premiums (taxable lines)** — 7% _(**Refusal R-MB-1**.)_ - **Electricity / natural gas (residential)** — Exempt _(Commercial use generally taxable.)_ - **Base for RST** — **Base for RST**: the *selling price before GST*. RST is NOT calculated on the GST-inclusive price. Do not compound. Worked: a CAD $1,000 software licence sold to a Winnipeg customer: GST (5%) = $50.00; RST (7%) = $70.00 (on the $1,000 base, NOT on $1,050); Customer pays $1,120.00 ## 4. Registration ### Who must register - **Registration requirements** — A person must register and collect RST if they: 1. **Carry on business in Manitoba** and make taxable sales of goods or taxable services, OR 2. **Are a non-resident / out-of-province vendor** that meets the **economic nexus** test introduced effective **1 December 2021** under amendments to the Retail Sales Tax Act: Makes taxable retail sales in Manitoba exceeding **CAD $10,000** in the prior 12 months, AND Solicits orders from Manitoba purchasers (e.g., via website, advertising), AND Causes goods to be delivered to Manitoba. 3. **Online accommodation platforms** (e.g., short-term rental marketplaces) must register and collect RST + lodging tax on accommodations situated in Manitoba. 4. **Marketplace facilitators** that enable third-party sales of taxable goods to Manitoba purchasers must register and collect RST on facilitated sales (post-2021 rules). 5. **Audio and video streaming services** with Manitoba subscribers — explicit listing as taxable specified service post-2021. _(amendments to the Retail Sales Tax Act, effective 1 December 2021)_ ### Process - **Registration process** — Register through **TAXcess** (online) or paper Form MBT-RL1. No registration fee. Manitoba Finance issues a 7-digit RST number. Assigns filing frequency on registration based on expected tax to collect. ## 5. Taxable supplies — what RST applies to ### Tangible personal property (TPP) - **TPP default rule** — Default: all sales of TPP delivered to a Manitoba purchaser are taxable unless an exemption applies. ### Specified taxable services (key for software / professional services firms) Manitoba taxes **more services than most other PST provinces**. Notable taxable services: **Specified taxable services table** | Service | Taxable? | Note | | --- | --- | --- | | **Legal services** | Yes — 7% | Manitoba is one of the few provinces taxing legal services. | | **Accounting services** | Yes — 7% | Bookkeeping, tax prep, audit, advisory — RST applies. | | **Security and investigation services** | Yes — 7% | | | **Telecommunications** | Yes — 7% | Includes wireless, internet, long-distance. | | **Audio / video streaming services** | Yes — 7% | Post-2021. | | **Software** — packaged / shrink-wrap | Yes — 7% | | | **Software** — custom-developed for a single customer | **Exempt** if the development is bespoke and not resold | Strict test; see Bulletin 057. | | **Software-as-a-Service (SaaS)** | Yes — 7% | Treated as taxable software / specified service when accessed by MB users. | | **Cloud computing / data storage** | Generally taxable | Where the customer is in MB. | | **Architectural / engineering services** | **Exempt** (services), but TPP components taxable | | | **Personal services** (haircuts, massage) | Exempt | Unlike Saskatchewan. | | **Repair / installation services to TPP** | Yes — 7% | | | **Dry cleaning / laundry** | Yes — 7% | | - **Legal services** — Yes — 7% _(Manitoba is one of the few provinces taxing legal services.)_ - **Accounting services** — Yes — 7% _(Bookkeeping, tax prep, audit, advisory — RST applies.)_ - **Security and investigation services** — Yes — 7% - **Telecommunications** — Yes — 7% _(Includes wireless, internet, long-distance.)_ - **Audio / video streaming services** — Yes — 7% _(Post-2021.)_ - **Software — packaged / shrink-wrap** — Yes — 7% - **Software — custom-developed for a single customer** — **Exempt** if the development is bespoke and not resold _(Strict test; see Bulletin 057.)_ - **Software-as-a-Service (SaaS)** — Yes — 7% _(Treated as taxable software / specified service when accessed by MB users.)_ - **Cloud computing / data storage** — Generally taxable _(Where the customer is in MB.)_ - **Architectural / engineering services** — **Exempt** (services), but TPP components taxable - **Personal services (haircuts, massage)** — Exempt _(Unlike Saskatchewan.)_ - **Repair / installation services to TPP** — Yes — 7% - **Dry cleaning / laundry** — Yes — 7% This breadth — particularly **legal, accounting, security, telecom, SaaS, and streaming** — is the single biggest difference between MB RST and the more limited Saskatchewan PST base. ## 6. Exemptions Common exemptions (this is not exhaustive — confirm against current MB Finance bulletins): **Basic groceries** (parallels GST zero-rating; prepared meals and snack food remain taxable). **Prescription drugs and dispensing fees**; certain over-the-counter drugs where Schedule listed. **Medical and dental devices** prescribed (insulin, prosthetics, hearing aids, eyeglasses with prescription). **Residential rent** (long-term housing). **Children's clothing and footwear** (sized for children up to age 14, within Bulletin 027 size schedule). **Books** — printed books with an ISBN are exempt. **Farm implements and production inputs** held under a valid Farm Use Certificate. **Manufacturing production equipment** under the production-input exemption (Bulletin 030). **Goods purchased for resale** — provide RST number on the purchase order (resale exemption). **Sales to status Indians / First Nations on-reserve** with delivery to reserve (**Refusal R-MB-7** if facts are not clear). **Sales exported out of Manitoba** with documented delivery to another jurisdiction. When relying on an exemption, document it: certificate, RST number of the purchaser, delivery records, or prescription as applicable. Audit risk is concentrated here. ## 7. Filing — TAXcess ### Mechanics - **Filing mechanics** — File and pay through **TAXcess** (`https://taxcess.gov.mb.ca/`). Return due **on or before the 20th day of the month following the end of the reporting period**. Late filing: penalty (typically 10% of tax owing) + interest. Returns must be filed even if **NIL** (no sales / no tax collected). _(https://taxcess.gov.mb.ca/)_ ### Frequencies **Filing frequencies table** | Annual RST collected | Frequency | | --- | --- | | > CAD $5,000 / month average | Monthly | | CAD $500 – $5,000 / month | Quarterly | | < CAD $500 / month | Annually | - **> CAD $5,000 / month average** — Monthly - **CAD $500 – $5,000 / month** — Quarterly - **< CAD $500 / month** — Annually Manitoba Finance reassesses frequency periodically. ### Key boxes on the return - **Return line items** — 1. Gross sales 2. Less: exempt / non-taxable sales 3. Net taxable sales 4. RST collected (line 3 × 7%, reconciled to books) 5. Taxable purchases — self-assessed RST 6. Total tax payable 7. Less: vendor commission (if applicable and on-time) 8. Net remittance 9. Accommodation / lodging tax (separate line — 5%) ## 8. Combined GST + RST Manitoba did NOT harmonize with the federal GST. The two taxes are **stacked, not combined**: 5% federal GST/HST (administered by CRA); 7% provincial RST (administered by Manitoba Finance); **Effective rate on a standard taxable supply = 12%** - **Critical practitioner points** — 1. RST is calculated on the **price excluding GST** — do not compound the two taxes. 2. There is **no input tax credit** for RST. Tax paid on business inputs is a cost of doing business, unless a resale or production exemption applies and a valid exemption was claimed at the time of purchase. 3. A registrant must file **two separate returns**: GST/HST return with CRA, and RST return with Manitoba Finance (TAXcess). Reconcile the gross sales line between the two — auditors compare. 4. Invoices to Manitoba customers should show GST and RST as separate line items. ## 9. Worked example — Winnipeg software company **Facts** Acme Software Inc. is a Manitoba corporation with its office in Winnipeg. Quarterly RST filer. Q1 2025 (Jan 1 – Mar 31): **Revenue streams table** | Revenue stream | Gross | Customer location | RST treatment | | --- | --- | --- | --- | | SaaS subscriptions to MB-based clients | $80,000 | MB | Taxable @ 7% | | SaaS subscriptions to Ontario clients | $120,000 | ON | Out-of-scope for MB RST (ON has HST, separate analysis) | | Custom software development for one Winnipeg client (bespoke, not resold) | $40,000 | MB | **Exempt** under custom-software carve-out (Bulletin 057) — document the bespoke nature | | Off-the-shelf software licences sold to MB clients | $15,000 | MB | Taxable @ 7% | | Telecom resale (managed Wi-Fi) to MB clients | $5,000 | MB | Taxable @ 7% (telecom is a specified taxable service) | | Sales to a Saskatchewan client | $10,000 | SK | Out-of-scope for MB RST (SK PST analysis separate) | | **Total** | **$270,000** | | | Self-assessed RST on out-of-province purchases used in MB: Cloud hosting from a US vendor not registered for MB RST: $8,000 of MB-attributable usage → self-assess 7% = $560. **Computation table** | Line | Amount | | --- | --- | | Gross sales | $270,000 | | Less: exempt / out-of-scope sales (ON + SK + custom dev exempt) | $(170,000) | | **Net MB taxable sales** | **$100,000** ($80k SaaS MB + $15k off-the-shelf + $5k telecom) | | RST collected (7% × $100,000) | $7,000 | | Self-assessed RST on imports | $560 | | **Total RST payable** | **$7,560** | | Less: vendor commission (capped; assume $58 entitled if filing on time) | $(58) | | **Net remittance** | **$7,502** | **Filing** Return + payment due **20 April 2025** via TAXcess. File even if NIL. Reconcile gross sales ($270,000) to the GST/HST return filed with CRA for the same period — gross figures must agree. **Documentation to retain** Invoices showing GST and RST separately for the MB taxable streams. Engagement letters / development contracts evidencing the bespoke nature of the $40,000 custom development (to support the exemption on audit). Out-of-province delivery / customer-location evidence for the $120,000 ON and $10,000 SK sales (IP logs, billing address, signed delivery certificates). Workpaper showing the self-assessment computation for the cloud hosting. ## 10. Conservative defaults - **Conservative default rules** — When preparing an MB RST return, default to the more cautious treatment whenever facts are ambiguous: 1. **Customer location uncertain** → treat as MB and tax at 7%. Document the basis; refund mechanism exists if later substantiated as out-of-province. 2. **Service category uncertain** (e.g., is it custom software or off-the-shelf?) → treat as taxable. The exemption is the carve-out; the default rule is taxability for the specified service categories. 3. **Bundled supplies** with a taxable element ≥10% of value → tax the entire bundle unless apportionment is clearly supportable (and if it isn't, escalate per **R-MB-6**). 4. **Self-assessment on imports** → when in doubt, self-assess. Under-assessment penalties exceed the cost of capital on a slight over-remittance. 5. **Exemption certificates** → do not accept verbal claims. Require the purchaser's RST number or a signed exemption certificate retained for **6 years** (statutory retention period under the Act). 6. **Filing NIL returns** → file even when no tax was collected. Missed NIL returns trigger non-filer penalties. 7. **Reconciliation to GST/HST** → always reconcile gross taxable sales between the federal and provincial returns before filing. Discrepancies are the #1 audit trigger. 8. **Vendor commission** → only claim if return AND remittance are on time. Late filings forfeit the commission and add penalty. 9. **Marketplace facilitators** → if the client sells through a marketplace, confirm whether the marketplace is collecting RST on the client's behalf. Double-collection or double-non-collection are both common errors post-2021. 10. **Out-of-province sellers** approaching the $10,000 threshold → register before crossing it; back-registration with collected-but-unremitted tax is materially worse than proactive registration. _(Retail Sales Tax Act — statutory retention period)_ ## 11. Sources **The Retail Sales Tax Act**, C.C.S.M. c. R130 — primary statute. **The Retail Sales Tax Regulation**, Man. Reg. 75/88 R. **Manitoba Finance — Taxation Division**, RST information bulletins, including: Bulletin No. 005 — Information for Contractors (Real Property); Bulletin No. 027 — Children's Clothing and Footwear; Bulletin No. 030 — Manufacturing Production Equipment; Bulletin No. 047 — Sales to First Nations and First Nations Persons; Bulletin No. 057 — Computer Software (custom vs off-the-shelf); Bulletin No. 064 — Specified Services (legal, accounting, security). **TAXcess online portal** — `https://taxcess.gov.mb.ca/` — registration, filing, and payment. **Budget 2021 (Manitoba)** — economic nexus / marketplace facilitator amendments effective 1 December 2021. **Manitoba Finance Notices** issued periodically for rate, base, and procedural changes — always check for notices issued after this skill's tax year (2025) before filing. ## Skill version footer *Skill version 1.0 — tax year 2025. Verification pending (Canadian provincial sales tax specialist). Federal GST/HST handled by the CRA / `ca-gst-hst` skill; this skill covers Manitoba RST only.* ## Talk to a verified accountant This skill is a tool, not an engagement. Every taxpayer's situation is different, and the rules in the skill may not match your specific facts. To speak with one of the licensed accountants who verifies skills for your jurisdiction — **no liability on either side until you and the accountant sign a formal engagement letter** — book a free 30-minute call: **→ [Book a call](https://calendly.com/openaccountants-info/30min)** We'll route you to the named verifier covering your country or state. You can also see the full list of verified accountants at [openaccountants.com/network](https://openaccountants.com/network).