Our client is developing multiple standalone dwellings. Based on the nature and scale of the project, the activities may constitute an enterprise. However, the client’s current intention is to retain the properties as long-term rental properties for more than 5 years, so no GST credits have been claimed on the development costs, as the intended supply is input taxed residential rental.
If the client later changes intention after 4 years and decides to sell the properties, and the sale becomes subject to GST, can the client still claim GST credits on the earlier development costs? Or is the client prevented from doing so because of the 4-year time limit for claiming GST credits? In that case, would the issue be dealt with under the GST adjustment provisions rather than a late credit claim?