CRA GST/HST Cleaning Contractor for Commercial Buildings, Office Towers & Retail Stores Audit — Montreal CPA Firm Near You: Defending Taxable Services, Multi-Site Contracts, Subcontractors & ITCs

A CRA GST/HST Commercial Building Cleaning Audit targets:

• office-tower cleaning contractors
• janitorial crews for commercial buildings
• retail store cleaning companies
• mall/night-shift cleaning teams
• medical & clinic janitorial providers
• industrial facility cleaning
• commercial washroom sanitation
• warehouse cleaning contractors
• subcontract janitorial crews

Commercial cleaning is one of CRA’s highest-audit-volume sectors, because the industry is:

• 100% taxable (no exemptions)
• multi-crew, multi-location and multi-contract
• filled with subcontracted cleaners
• invoice-heavy with poor documentation
• operating overnight or without direct supervision
• dependent on high volumes of supplies and equipment

Mackisen CPA Montreal specializes in defending commercial cleaners by reconstructing contract-by-contract evidence, validating subcontractors, correcting GST/HST treatment, and rebuilding ITC documentation.

Legal Foundation

Excise Tax Act

• s.165 — ALL cleaning, janitorial, sanitation and building-maintenance services are fully taxable

• s.221 — GST/HST must be charged and collected

• s.169 — ITCs allowed only with full receipts + proof of payment

• s.141.01 — allocation rules for shared tools, vans, equipment

• Schedule IX — GST/HST rate based on property location

• s.123(1) — “cleaning,” “maintenance,” “real property service”

Case Law & CRA Rulings

• Commercial cleaning = 100% taxable, no exemptions

• Sanitation/facility cleaning = taxable labour

• Royal Bank v. Canada — missing invoice details invalidate ITCs

• Northwest Company Inc. — supplier invoices must meet legal requirements

Learning insight: No “healthcare exemption” exists for cleaning clinics, offices or commercial buildings — ALL cleaning is taxable.

Why CRA Audits Commercial Cleaning Contractors

Revenue Risks

• GST/HST not charged on cleaning contracts
• corporate cleaning bundles not itemized correctly
• cash/e-transfer payments to crews not invoiced
• missed GST on after-hours emergency cleaning
• retail/warehouse cleaning miscoded
• deposits not reported
• large monthly retainer contracts underreported
• multi-site chain contracts not matched to GST filing periods

Subcontractor Risks

• subcontract cleaners lacking GST numbers
• helpers paid cash
• invalid subcontractor invoices
• T4A non-compliance
• unregistered night-shift subcontract crews

ITC Risks

• missing invoices for:
– chemicals, sanitation products
– industrial vacuums, floor polishers
– PPE, gloves, masks
– garbage bags & supplies
– vehicle costs (fuel, maintenance)
– commercial cleaning equipment rentals
• imported cleaning machines without GST self-assessment
• personal-use equipment claimed
• supply purchases not tied to contracts

Operational Risks

• no cleaning logs for each site
• supervisor reports missing
• multi-crew coverage not documented
• inconsistent cleaning frequency vs contract
• “flat-rate” corporate contracts not tied to labour hours
• poor bookkeeping due to night-shift operations

High-risk operators:

• office-tower contractors

• mall & retail cleaners

• industrial cleaning teams

• clinic/medical janitorial providers

• subcontract-heavy cleaning firms

Learning insight: CRA assumes underreported revenue + invalid subcontractors + missing ITCs unless evidence disproves it.

CRA Commercial Cleaning Audit Process

1. CRA requests:
   – contracts for each building/site
   – invoices (monthly, per-visit, emergency, special services)
   – subcontractor invoices + GST numbers
   – supply receipts
   – equipment purchase/rental invoices
   – bank & e-transfer statements
   – employee/subcontractor schedules
   – cleaning logs
   – ITC spreadsheets
   – import receipts for machines

2. CRA tests:
   • GST/HST charged correctly on ALL services
   • subcontractor registration & invoice validity
   • ITC documentation completeness
   • logs → invoices → deposits → GST return consistency
   • chemical/supply purchases vs volume of work
   • imported machines → self-assessment
   • multi-location contracts matched to reported revenue

3. CRA issues Proposed Audit Adjustment.

4. Mackisen CPA prepares complete legal + documentary defense.

Learning insight: CRA rebuilds your business using multi-site logs, corporate contracts, supply usage & deposits.

Mackisen CPA’s Commercial Cleaning Audit Defense Strategy

• create a Commercial Cleaning Tax Matrix (monthly retainer, per-visit, emergency, sanitation add-ons)
• rebuild GST/HST-compliant invoices
• validate subcontractor GST/HST registration
• reconstruct a full ITC binder (chemicals, equipment, supplies, vehicle, PPE)
• reconcile multi-site logs → invoices → deposits → GST filings
• correct GST/HST logic for QC/ON/Atlantic operations
• rebuild imported-equipment self-assessment
• defend vehicle & equipment ITCs with allocation worksheets
• prepare a CPA-certified CRA audit binder
• negotiate penalty & interest reduction

Learning insight: These audits are won through site-based logs, subcontractor control & ITC rigor.

Common CRA Findings in Commercial Cleaning Audits

• GST/HST not charged on monthly contracts
• subcontract cleaners unregistered for GST
• ITCs denied due to missing receipts
• imported machines missing GST
• bank deposits > reported revenue
• supply purchases inconsistent with work volume
• emergency cleaning not invoiced
• multi-location tax errors

Learning insight: CRA’s largest adjustments come from invoice defects, subcontractor issues & underreported revenue.

Real-World Results

• A commercial cleaner avoided a $402,000 reassessment after Mackisen CPA rebuilt site logs & subcontract files.
• A clinic-cleaning company reversed a $238,000 ITC denial through full PPE/chemical/equipment documentation.
• A mall janitorial contractor eliminated penalties by correcting GST on emergency-cleaning services.
• A multi-site cleaning firm cleared CRA findings through deposit→invoice→site-log reconciliation.

Learning insight: CRA backs down when presented with organized, building-by-building documentation.

SEO Optimization & Educational Value

Primary keywords: GST/HST commercial cleaning audit, CRA janitorial contractor audit, cleaning GST rules Canada, Mackisen CPA Montreal
Secondary keywords: subcontract cleaner GST, commercial ITC denial, sanitation GST audit, multi-site cleaning GST/HST

Learning insight: Commercial-cleaning audits rank extremely high in SEO because of the large contractor base.

Why Mackisen CPA Montreal

With 35+ years defending commercial cleaning, janitorial & sanitation contractors, Mackisen CPA Montreal is Québec’s #1 authority in GST/HST cleaning-sector audits.
We understand site logs, corporate contracts, subcontractor systems, supply usage & CRA methodology thoroughly.

Learning insight: These audits require job-log accuracy, subcontractor compliance & ITC discipline — strengths of Mackisen CPA.

Call to Action

If CRA is auditing your commercial cleaning, janitorial, multi-site building-maintenance, or office-tower sanitation business, contact Mackisen CPA Montreal immediately:

📞 514-276-0808
📧 info@mackisen.com
🌐 mackisen.com

Learning Conclusion:

A CRA GST/HST Commercial Building Cleaning Audit tests taxable labour, subcontractor compliance, ITC documentation, multi-site logs & deposit reconciliation.
Mackisen CPA Montreal ensures full protection from reassessments.