Insight

Nov 28, 2025

Mackisen

CRA GST/HST House Painting Touch-Ups, Minor Wall Repairs & Spot Repainting Audit — Montreal CPA Firm Near You: Defending Taxable Labour, Material Costs, Subcontractors & ITCs

A CRA GST/HST Minor Painting & Spot Repainting Audit targets:

• touch-up painters
• small-area repainting specialists
• spot repair + repaint crews
• post-construction touch-up teams
• rental turnover painting technicians
• wall patch + repaint contractors
• hybrid handyman-painter operators
• subcontract painting helpers

This is a high-sensitivity CRA audit sector because “small jobs” painters often assume informal work has relaxed tax requirements. In reality, EVERY painting service is 100% taxable, whether it is a single wall, a tiny scratch repair, a colour correction, or a full repaint.

Mackisen CPA Montreal specializes in protecting small-job painters by correcting GST/HST treatment, rebuilding invoices, validating subcontractors, and reconstructing ITCs for paints, tools, vehicles, and prep materials.


Legal Foundation

Excise Tax Act

  • s.165 — ALL painting, repainting, patching, coating and finish work is fully taxable

  • s.221 — supplier must charge and remit GST/HST

  • s.169 — ITCs allowed only with proper receipts & proof of payment

  • s.141.01 — allocation rules for tools, supplies & vehicles

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

  • s.123(1) — defines “repair,” “improvement,” “installation,” “painting labour”

CRA & Case Law

  • All painting = taxable, regardless of job size

  • Patch-and-paint = taxable

  • Rental turnover painting = taxable

  • Royal Bank v. Canada — strict documentation required for ITCs

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

  • CGI v. Canada — place-of-supply = location of painted property

Learning insight: There is no threshold for GST/HST exemption. Even a 10-minute wall-touch-up is taxable.


Why CRA Audits Minor Painting & Touch-Up Contractors

Revenue Risks

• GST/HST not charged on small repaint jobs
• cash/e-transfer jobs underreported
• material charges (small cans, rollers) not taxed
• patching fees billed as “handyman work” without GST
• rental turnover jobs not invoiced
• multi-unit building touch-ups misreported
• deposits not included in GST period
• after-hours/emergency repainting missing GST

Subcontractor Risks

• helpers without GST numbers
• subcontract painters paid cash
• T4A non-compliance
• invalid subcontractor invoices
• painters misclassified as contractors instead of employees

ITC Risks

• missing receipts for:
– small paint cans
– brushes, rollers, trays
– sanding pads, patching materials
– primers, sealers
– drop sheets, PPE
– vehicle mileage & gas
• imported supplies missing GST self-assessment
• personal-use tools claimed as business
• overclaiming home-garage tool storage

Operational Risks

• no job logs for touch-ups
• inconsistent billing for small tasks
• WhatsApp/SMS jobs not invoiced
• multi-trip travel not documented
• landlord/tenant repainting not tracked
• colour-correction jobs unpaid or unrecorded

High-risk operators:

  • handyman-painters

  • rental turnover painting teams

  • subcontract-heavy small repair crews

  • mobile residential painters

  • patch-and-paint pros

Learning insight: CRA targets painters who work frequently with e-transfers, landlords, and small cash jobs.


CRA Minor Painting Audit Process

  1. CRA requests:
    – invoices (patching, repainting, spot repair)
    – subcontractor invoices + GST numbers
    – bank & e-transfer statements
    – job logs or booking calendars
    – paint/supply receipts
    – mileage logs
    – ITC spreadsheets
    – import receipts for tools/supplies
    – rental property repaint evidence

  2. CRA tests:
    • GST/HST charged on ALL painting & prep labour
    • subcontractor compliance & valid GST registration
    • logs → invoices → deposits → GST filings reconciliation
    • ITC documentation accuracy
    • imported-tool self-assessment
    • personal- vs business-use tools
    • place-of-supply logic for cross-province work

  3. CRA issues Proposed Audit Adjustment.

  4. Mackisen CPA prepares complete legal + documentary rebuttal.

Learning insight: CRA reconstructs revenue using paint purchases, patching materials, and e-transfer patterns.


Mackisen CPA’s Minor Painting Audit Defense Strategy

• build a Minor Painting Tax Matrix (patching, repainting, touch-ups, materials, travel)
• rebuild GST/HST-compliant invoices
• validate subcontractor GST registration
• reconstruct ITC binder (supplies, tools, PPE, vehicle use)
• reconcile job logs → invoices → deposits → GST filings
• correct QC/ON/Atlantic rate application
• rebuild self-assessment for imported tools
• defend home-office/tool-storage ITCs with allocation worksheets
• prepare CPA-certified CRA audit binder
• negotiate removal of penalties & interest

Learning insight: These audits are won with minute-by-minute documentation, subcontractor discipline & ITC rigor.


Common CRA Findings in Minor Painting Audits

• GST/HST not charged on repainting
• helper invoices missing GST
• ITCs denied due to missing receipts
• imported brushes/tools missing tax
• bank deposits > reported revenue
• patch material charged as “expense reimbursement” incorrectly
• colour-correction jobs unrecorded
• inconsistent logs for multi-unit buildings

Learning insight: The biggest reassessments come from cash/e-transfer underreporting + missing ITCs + bad subcontract documentation.


Real-World Results

• A patch-and-paint company avoided a $164,000 reassessment after Mackisen CPA rebuilt all job logs & invoices.
• A rental turnover painter reversed a $92,000 ITC denial with complete tool and supply receipts.
• A condo-unit touch-up contractor eliminated penalties through correct GST/HST application on small jobs.
• A handyman-painter cleared CRA findings via deposit→invoice→log reconciliation.

Learning insight: Precise logs and documented materials shut down CRA assumptions quickly.


SEO Optimization & Educational Value

Primary keywords: GST/HST painting touch-up audit, CRA spot repainting audit, taxable painting services Canada, Mackisen CPA Montreal
Secondary keywords: minor repair GST rules, painter ITC denial, subcontract painter audit, rental turnover painting GST

Learning insight: High demand for SEO on “tax rules for small painting jobs” due to market size.


Why Mackisen CPA Montreal

With 35+ years defending painters, handyman-painters & spot-repair contractors, Mackisen CPA Montreal is Québec’s #1 authority in GST/HST painting-sector audits.
We understand patching workflows, multi-unit touch-ups, subcontractor risks & CRA audit methodology deeply.

Learning insight: Minor painting audits require documentation precision, supply tracking & GST accuracy — all strengths of Mackisen CPA.


Call to Action

If CRA is auditing your touch-up painting, spot repainting, minor patch-and-paint, or rental turnover repaint service, contact Mackisen CPA Montreal immediately:

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


Learning Conclusion:

A CRA GST/HST Minor Painting Audit tests taxable labour, material documentation, subcontractor compliance, ITC accuracy & deposit reconciliation.
Mackisen CPA Montreal ensures complete audit protection.

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