CRA GST/HST Audit 2025 — Protect Your Business, Defend Your Credits, and Stop Reassessments

For Canadian business owners, a CRA GST/HST audit can feel like walking into a minefield. One wrong step—an incomplete invoice, a mismatched credit, or a missing supplier registration—can lead to a full reassessment, penalties, and years of interest. In 2025, CRA’s automated GST/HST audit system cross-references millions of transactions instantly, flagging “irregularities” that trigger audits even for honest, compliant businesses.

The CRA’s goal is simple: find under-reported tax or deny Input Tax Credits (ITCs)—and they rarely back down without evidence. But with professional representation and a detailed defense, most audits can be successfully defended or resolved before penalties apply. At Mackisen CPA Auditors Montreal, we stand between your business and the CRA, preparing precise records, validating every claim, and ensuring your rights are protected throughout the process.

We don’t wait for CRA to dictate your outcome—we take control of it.

Legal and Regulatory Framework

Excise Tax Act (Canada)

• Section 296(1): Authorizes CRA to reassess GST/HST based on audit findings.

• Section 225(1): Allows businesses to claim Input Tax Credits (ITCs) on purchases made for commercial activity.

• Section 286: Requires registrants to keep invoices, receipts, and contracts to support GST/HST filings.

• Section 296(2): Gives taxpayers 90 days to object to CRA audit reassessments.

Tax Administration Act (Quebec)
Allows Revenu Québec to conduct parallel QST audits, reassessments, and ITC/QST credit reviews on behalf of the CRA in Quebec.

Mackisen ensures your defense addresses both CRA and Revenu Québec simultaneously to avoid duplication and double penalties.

Key Court Decisions

North Shore Power Group v. The Queen (2018): CRA must consider valid documentation proving ITCs, even if submitted after audit.
Bédard v. The Queen (2022): Missing invoices don’t automatically disqualify ITCs if transactions are legitimate and can be proven.
Guindon v. Canada (2015): CRA penalties can apply for careless filings but may be reduced or cancelled with proper appeal and representation.
Les Entreprises XY v. The Queen (2020): Taxpayers can defend against GST/HST reassessments through consistent accounting and supplier verification.

These cases show that facts and documentation—not CRA assumptions—determine the final result.

Why CRA Conducts GST/HST Audits

CRA uses predictive analytics to identify businesses most likely to have reporting errors or compliance gaps. The most common 2025 GST/HST audit triggers include:

• Repeated Input Tax Credit (ITC) refund claims.

• Large ITCs relative to revenue.

• Transactions with unregistered or high-risk suppliers.

• Inconsistent reporting between GST/HST, income tax, and QST filings.

• Late or amended returns.

• Cash-heavy or subcontract-based industries (construction, trucking, consulting).

Even a small documentation error can cause CRA to deny credits and reassess multiple years at once.

Mackisen’s GST/HST Audit Defense and Resolution Strategy

1. Pre-Audit Review: Analyze all CRA requests and identify audit red flags before documents are submitted.

2. Evidence Compilation: Gather, verify, and organize invoices, receipts, and supplier registration proof.

3. Reconciliation Analysis: Match GST/HST returns to income statements, QST filings, and general ledger data.

4. Audit Representation: Communicate directly with CRA auditors on your behalf—so you never face them alone.

5. Post-Audit Resolution: File formal objections or appeals if CRA issues a reassessment or denies ITCs.

Our defense strategy neutralizes CRA’s assumptions before they turn into financial consequences.

Real Client Experience

A Montreal construction firm was hit with a CRA GST/HST reassessment of $143,000 after denied ITCs. Mackisen provided supplier verification and reconstructed records—CRA reversed 100% of the adjustments.
A Quebec wholesaler faced a $62,000 dual CRA/Revenu Québec audit. Mackisen identified duplicate entries in CRA’s system, reducing the liability to $4,500 and securing penalty relief.

Common Questions

Can CRA deny ITCs during an audit without warning? Yes, but Mackisen ensures your rights are upheld through formal objection and appeal procedures.
How long does a CRA GST/HST audit last? From several weeks to several months—Mackisen keeps your file organized and audit-ready from day one.
What if my supplier wasn’t registered for GST/HST? CRA may deny credits, but we can prove good faith and legitimate business use to reinstate them.
Can I appeal a GST/HST reassessment? Absolutely. Mackisen files objections and negotiates directly with CRA’s Appeals Division.

Why Mackisen

At Mackisen CPA Auditors Montreal, we’ve built our reputation on defending clients from unfair CRA and Revenu Québec GST/HST audits. Our auditors and tax lawyers use evidence-based strategies to dismantle weak CRA positions, restore ITCs, and protect your cash flow.

We act fast, prepare thoroughly, and fight fearlessly—because when CRA audits your business, Mackisen protects what you’ve built.

Call Mackisen CPA Auditors Montreal today for your 2025 GST/HST Audit Defense Consultation. The first meeting is free, and your protection starts immediately.