News Summary

In a significant legal win for Shopify, the Federal Court of Canada dismissed the Canada Revenue Agency’s (CRA) request for six years of data on Shopify merchants. This decision could embolden other companies to challenge similar CRA data requests. The CRA had used an ‘unnamed persons requirement’ (UPR) to demand personal information and business data of Shopify merchants, a mechanism previously employed successfully with companies like eBay and PayPal. However, the court found that the CRA failed to demonstrate that the Shopify merchants constituted an ‘ascertainable’ group. Shopify’s CEO, Tobi Lütke, criticized the CRA’s request as an overreach. The court ruling stated the request was overly broad and not clearly defined, which violated the criteria for a valid UPR. The CRA was also ordered to pay Shopify $90,000 in legal costs. This case may set a precedent for other companies to resist CRA’s demands for client data.