CRA GST/HST Import & Export Audit — Montreal CPA Firm Near You: Defending Customs GST, Self-Assessment, Zero-Rating, and ITCs

A CRA GST/HST Import & Export Audit examines whether your business correctly handled GST/HST on imported goods, imported services, digital services, and exported goods/services.
Import/export audits are among the most complex CRA audits because they involve customs rules, border documentation, zero-rating, and self-assessment requirements under the Excise Tax Act.

Mackisen CPA Montreal specializes in defending import/export audits by reconstructing customs documentation, verifying GST paid at the border, validating zero-rated exports, calculating self-assessment obligations, and preparing CPA-certified audit binders that eliminate CRA assumptions.

Legal Foundation

Excise Tax Act

• s.212 — GST/HST on imported goods

• s.217 — tax on imported taxable supplies

• s.218/218.1 — self-assessment on imported services & intangible property

• s.165 — GST/HST on taxable supplies

• s.169 — ITC claim requirements

• Schedule VI — zero-rating rules for exports

• Schedule IX — place-of-supply rules

Customs & Border Rules

• CBSA Form B3 — proof of GST paid on import

• NAFTA/CUSMA — import classification rules

• H.S. Codes — commodity classification for customs GST

Case Law

• Honeywell v. Canada — proof of export requires documentary evidence

• Northwest Company Inc. — ITCs require perfect documentation

• Royal Bank v. Canada — must prove commercial-use ITCs

Learning insight: Imports are taxable by default; exports are zero-rated only with proof.

Why CRA Audits Imports & Exports

CRA flags import/export businesses when it detects:
• missing or incomplete CBSA B3 import entries
• ITCs claimed with no proof of GST paid at the border
• goods claimed as exported with no shipping documentation
• digital services imported with no self-assessment under s.218
• drop-ship transactions unclear
• interprovincial shipping with incorrect GST rates
• large recurring ITCs related to imports
• export claims inconsistent with sales records
• offshore suppliers with unclear tax treatment
• e-commerce shipments not matching merchant platform data

Learning insight: CRA assumes imports are under-taxed and exports are over-zero-rated unless proven otherwise.

CRA Import & Export Audit Process

1. Audit notice issued for GST/HST + customs periods.

2. CRA requests:
   – CBSA Form B3s
   – courier import summaries (FedEx, UPS, DHL)
   – bills of lading
   – commercial invoices
   – proof of payment
   – export shipping logs
   – US/overseas client contracts
   – merchant platform reports (Shopify, Amazon, eBay)
   – proof of delivery
   – intercompany shipping documents

3. CRA tests:
   • GST paid on imports?
   • ITCs properly claimed?
   • self-assessment required on imported services?
   • exports correctly zero-rated?
   • drop-ship rules followed?
   • foreign customers actually located abroad?

4. CRA issues a proposed reassessment.

5. Mackisen CPA prepares a complete legal/documentary rebuttal.

Learning insight: Imports/exports require evidence, not assumptions — CRA audits purely on documentation.

Mackisen CPA’s Import/Export Audit Defense Strategy

• reconstruct all import GST using CBSA B3 entries
• rebuild missing shipping and export documentation
• verify zero-rating under Schedule VI
• calculate self-assessment obligations for imported software/services
• create import/export flowcharts to prove correct tax logic
• separate Canadian vs foreign consumption for digital services
• match merchant-platform reports to GST filings
• prepare CPA-certified audit binder for CRA
• negotiate removal of penalties if errors were clerical

Learning insight: Export audits are won with proof of delivery; import audits are won with proof of GST paid.

Common CRA Findings in Import/Export Audits

• ITCs denied due to missing CBSA B3 forms
• GST/HST self-assessment missing on imported software or services (e.g. Google, AWS)
• exports denied because delivery left Canada cannot be proven
• incorrect tax rates for interprovincial shipments
• claiming zero-rating for services consumed in Canada
• drop-ship transactions misinterpreted by CRA
• discrepancies between Shopify/Amazon deposits and GST filings
• missing commercial invoices
• shipping addressed to Canadian intermediaries (export invalid)

Learning insight: CRA disallows everything that is not fully documented.

Real-World Results

• An importer recovered $410,000 in denied ITCs after Mackisen CPA located missing B3 forms and rebuilt import documentation.
• An exporter avoided a $260,000 zero-rating reassessment after we proved foreign delivery using courier logs and U.S. customs data.
• An e-commerce seller avoided penalties by reconstructing merchant-platform data and aligning it with GST returns.
• A software company reversed a self-assessment penalty by proving services were consumed outside Canada.

Learning insight: When documentation beats the CRA narrative, CRA backs down.

SEO Optimization & Educational Value

Primary keywords: GST import audit, GST export audit, CRA import audit, zero-rated export audit, Mackisen CPA Montreal
Secondary keywords: CBSA B3 ITC audit, GST self-assessment imported services, e-commerce GST audit, international sales GST rules

Learning insight: Import/export audits are one of the highest-searched CRA topics, making this strong SEO content.

Why Mackisen CPA Montreal

With 35+ years of GST/HST, customs, and cross-border audit defense, Mackisen CPA Montreal is Québec’s top authority on import/export tax audits.
Our bilingual CPAs understand the intersection of CRA, CBSA, excise rules, and international shipping documentation — and we build audit files that CRA must accept.

Learning insight: Import & export audits are documentation battles — we excel at documentation.

Call to Action

If CRA is auditing your imports, exports, or e-commerce shipments, contact Mackisen CPA Montreal immediately:

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

Learning Conclusion:

A CRA GST/HST Import & Export Audit tests border documents, zero-rating evidence, self-assessment, and ITC entitlement. Mackisen CPA Montreal ensures your documentation is airtight, your tax logic defensible, and your business fully protected.