CRA GST/HST Courier, Delivery & Last-Mile Services Audit — Montreal CPA Firm Near You: Defending Delivery Fees, Fuel Surcharges, Subcontract Drivers & ITCs

A CRA GST/HST Courier, Delivery & Last-Mile Services Audit targets businesses providing parcel delivery, same-day courier, restaurant delivery, medical courier, messenger services, e-commerce last-mile delivery, grocery delivery, and B2B logistics.

This sector is aggressively audited because delivery operations involve:
• fully taxable courier & delivery services (no exemptions)
• subcontracted drivers and gig-economy workers
• fuel surcharges, mileage fees, and zone fees
• high-volume micro-transactions
• multi-province deliveries
• imported SaaS tools (route planning, dispatch software) requiring s.218 self-assessment
• high ITCs for vehicles, fuel, insurance & maintenance
• inconsistent POS vs deposit patterns
• cross-platform revenue (Uber, DoorDash, Skip, Shopify, Amazon Flex)

Mackisen CPA Montreal specializes in defending courier and last-mile delivery audits by reconstructing delivery logs, validating subcontractor GST status, mapping tax rates, and preparing CRA-ready audit binders.

Legal Foundation

Excise Tax Act

• s.165 — GST/HST applies to all courier, messenger, transportation and delivery services

• s.221 — mandatory collection of GST/HST

• s.169 — ITC documentation requirements

• s.141.01 — allocation of mixed-use expenses

• Schedule IX — province-of-customer place-of-supply rules

• s.218/218.1 — self-assessment on imported digital services (routing apps, dispatch systems, SaaS tools)

Case Law

• Honeywell v. Canada — zero-rating requires strict proof

• UPS / FedEx Cases — delivery charges follow primary supply; courier service is taxable

• Royal Bank v. Canada — strict ITC documentary standards

• City of Calgary v. Canada — taxability depends on service destination

Learning insight: Delivery is always taxable—regardless of what is being delivered.

Why CRA Audits Courier & Last-Mile Delivery Companies

CRA flags delivery companies when it detects:

Revenue Risks

• GST/HST not charged on delivery fees
• cash/e-transfer deliveries underreported
• zone fees / mileage fees / heavy item fees missing GST
• inconsistent revenue from Uber/Skip vs GST returns
• Shopify/Amazon delivery payouts not reconciled
• multi-province deliveries misrated
• B2B courier contracts taxed incorrectly

Driver/Subcontractor Risks

• drivers without valid GST/HST numbers
• subcontractor invoices missing details
• employee vs contractor misclassification
• T4A or T5018 inconsistencies

ITC Risks

• ITCs claimed for:
– fuel
– vehicle repairs
– insurance
– tires
– dispatch software
– phones/tablets
– warehouse/office rent
… but missing invoice requirements
• personal vehicle expenses overclaimed
• imported SaaS tools missing s.218 GST self-assessment

Operational Risks

• GPS logs inconsistent with invoices
• zone-based fees incorrectly coded
• COD (cash on delivery) not fully reported
• delivery logs missing or incomplete
• shrinkage / lost parcel claims misclassified

High-risk operators:

• same-day couriers

• restaurant & grocery delivery fleets

• e-commerce last-mile companies

• independent courier contractors

• medical specimen courier services

• B2B delivery networks

• Amazon Flex / Uber Direct drivers

Learning insight: CRA assumes cash underreporting + invalid ITCs + subcontractor non-compliance unless proven otherwise.

CRA Courier/Delivery Audit Process

1. CRA requests:
   – delivery logs (GPS, route sheets)
   – platform reports (Uber, Skip, Amazon Flex, Shopify)
   – invoices & contracts
   – bank/e-transfer statements
   – fuel & vehicle invoices
   – subcontractor invoices
   – GST numbers for subcontractors
   – ITC spreadsheets
   – vehicle lease or purchase agreements
   – insurance records
   – dispatch/route software invoices

2. CRA tests:
   • whether GST/HST was charged on ALL delivery services
   • correct rate based on province delivered to
   • driver subcontractor compliance
   • validity of ITCs
   • personal vs business vehicle expense allocation
   • revenue completeness: logs ↔ deposits ↔ tax returns
   • whether COD or cash payments were omitted
   • imported SaaS → self-assessment compliance

3. CRA issues a Proposed Audit Adjustment.

4. Mackisen CPA prepares full documentary + legal defense.

Learning insight: CRA performs route-by-route analysis to catch missing GST and unreported trips.

Mackisen CPA’s Delivery & Last-Mile Audit Defense Strategy

• reconstruct Delivery Supply Tax Matrix (base fee, zone, mileage, surcharges)
• rebuild ITC binder for vehicles, fuel, software, equipment
• validate subcontractor GST numbers
• reconcile delivery logs ↔ platform payouts ↔ bank deposits
• correct place-of-supply for multi-province deliveries
• defend against CRA’s cash-job assumptions
• prepare CPA-certified audit binder
• negotiate removal of penalties & interest

Learning insight: Delivery audits are won with GPS/log reconstruction + invoice integrity + ITC proof.

Common CRA Findings in Delivery Audits

• GST/HST not charged on:
– delivery fees
– mileage fees
– heavy item fees
– zone surcharges
• ITCs denied for invalid fuel or vehicle invoices
• subcontractor drivers unregistered
• imported software (dispatch apps) missing self-assessment
• cash deliveries unreported
• platform revenue (Uber, Skip) not matching GST filings
• personal-use vehicles claimed
• multi-province deliveries misrated
• inconsistent logs from route to route

Learning insight: Most reassessments arise from invoice deficiencies + driver non-compliance + cash/e-transfer mismatches.

Real-World Results

• A courier fleet avoided a $340,000 reassessment after Mackisen CPA rebuilt GPS logs and corrected subcontractor GST documentation.
• A last-mile e-commerce delivery company reversed a $187,000 ITC denial by reconstructing vehicle and fuel invoices.
• A food delivery service eliminated penalties after reconciling Skip/Uber payouts with GST filings.
• A medical courier cleared CRA findings after mapping multi-province tax rules and reconstructing dispatch logs.

Learning insight: When documentation is CPA-organized, consistent, and GPS-supported, CRA backs down.

SEO Optimization & Educational Value

Primary keywords: GST/HST courier audit, CRA delivery audit, last-mile GST rules, Mackisen CPA Montreal
Secondary keywords: subcontractor driver GST, fuel ITC denial, Uber delivery GST audit, delivery platform tax rules

Learning insight: Delivery & courier audits are high-volume search topics — ideal for SEO authority and client acquisition.

Why Mackisen CPA Montreal

With 35+ years defending courier fleets, last-mile operators, gig-economy drivers, and delivery networks, Mackisen CPA Montreal is Québec’s #1 authority in GST/HST courier audit defense.
We understand routing logic, fuel ITCs, subcontractor networks, and CRA audit methodology intimately.

Learning insight: Courier audits require route reconstruction + ITC precision + subcontractor compliance — the Mackisen advantage.

Call to Action

If CRA is auditing your courier, delivery, or last-mile business, subcontractor invoices, ITCs, or route logs, contact Mackisen CPA Montreal immediately:

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

Learning Conclusion:

A CRA GST/HST Courier & Delivery Audit tests taxable delivery fees, subcontractor compliance, multi-province tax rates, ITC documentation, and platform payout accuracy.
Mackisen CPA Montreal ensures your entire delivery operation is fully defended from costly reassessments.