Insight

Nov 28, 2025

Mackisen

CRA GST/HST IT Consulting, Software Implementation & Tech Support Audit — Montreal CPA Firm Near You: Defending Service Classification, Subcontractors, Imported Software & ITCs

A CRA GST/HST IT Consulting & Tech Support Audit targets businesses offering:

• IT consulting
• software implementation
• cloud migration
• cybersecurity services
• helpdesk & tech support
• systems integration
• digital transformation services
• project management & IT architecture
• managed IT services (MSP)
• data recovery & networking
• remote support
• hardware installation & configuration

The IT consulting sector is highly audited due to:

• mixed taxable services
• imported SaaS tools requiring s.218 self-assessment
• subcontracted developers & consultants
• multi-province client base
• inconsistent GST/HST application on remote services
• bundled deliverables (consulting + software + support)
• large recurring ITCs
• multiple revenue streams (MSP, hourly, project, retainers)

Mackisen CPA Montreal specializes in defending IT consultants by mapping each supply, correcting tax rates, rebuilding ITC documentation, and preparing CRA-standard audit binders.


Legal Foundation

Excise Tax Act

  • s.165 — GST/HST applies to all IT consulting & tech support

  • Schedule IX — place-of-supply rules for interprovincial clients

  • s.221 — mandatory GST/HST collection

  • s.169 — ITC eligibility & documentation requirements

  • s.141.01 — mixed-use allocation rules

  • s.218 & 218.1 — self-assessment on imported software/SaaS

  • s.123(1) — definitions for “service,” “intangible,” “digital supply”

Case Law & CRA Guidance

  • Honeywell — zero-rating must be proven

  • City of Calgary v. Canada — province-of-consumption governs tax rate

  • Royal Bank v. Canada — incomplete invoices invalidate ITCs

  • CRA policy: software implementation is taxable; software resale may require different classification

Learning insight: IT consulting = 100% taxable unless supplied to a qualifying non-resident (rare and documentation-heavy).


Why CRA Audits IT Consultants & Tech Support Firms

CRA flags tech consulting firms when it detects:

Revenue Risks

• wrong GST/HST rate for out-of-province clients (ON/NB/NS/NL)
• services to foreign clients zero-rated without proof
• bundled deliverables not separated (consulting + software license + training)
• prep/analysis work for non-residents incorrectly zero-rated
• cloud migration taxed incorrectly
• MSP monthly retainers miscoded
• travel & onsite service fees not taxed
• progress billing mistakes

Subcontractor Risks

• subcontracted developers without GST numbers
• contractors issuing invalid invoices
• employee vs contractor misclassification
• large subcontractor expenses without documentation

ITC Risks

• missing invoices for:
– cloud services
– software subscriptions
– servers, laptops, monitors
– networking equipment
– cybersecurity tools
• imported SaaS missing s.218 self-assessment
• ITCs claimed on personal-use devices
• partial-use assets misallocated

Operational Risks

• inconsistent billing across projects
• project documentation not matching revenue
• retainer payments not reconciled
• cross-border payments misclassified
• time entries inconsistent with invoices

High-risk IT consulting profiles:

  • independent consultants

  • MSP/IT support companies

  • software implementers

  • cybersecurity firms

  • IT staffing contractors

  • cloud architecture teams

  • ERP/CRM implementation specialists

Learning insight: CRA assumes rate errors + invalid ITCs + subcontractor non-compliance in tech consulting unless disproven.


CRA IT Consulting Audit Process

  1. CRA requests:
    – client list with provinces/countries
    – contracts, SOWs, MSAs
    – invoices & timesheets
    – subcontractor invoices
    – SaaS/software invoices (Azure, AWS, Google Cloud, Atlassian, Microsoft 365, Adobe)
    – ITC spreadsheets
    – bank & Stripe/PayPal statements
    – project documentation
    – imported software records (self-assessment)

  2. CRA tests:
    • correct GST/HST rate by client province
    • zero-rating proof for non-residents
    • ITC documentation validity
    • imported software → self-assessment
    • subcontractor GST compliance
    • consistency between timesheets & invoices
    • personal vs business devices
    • bundled deliverable classification

  3. CRA issues Proposed Audit Adjustment.

  4. Mackisen CPA prepares complete CRA-standard audit defense.

Learning insight: CRA examines client location, service type, ITCs, subcontractor validity, and imported software.


Mackisen CPA’s IT Audit Defense Strategy

• create a Client Tax Rate Matrix for QC/ON/BC/Atlantic clients
• separate consulting vs implementation vs MSP support
• reconstruct ITC binder for software, hardware & SaaS
• validate subcontractor GST registration
• rebuild imported software tax self-assessment (s.218)
• reconcile invoices → deposits → GST filings
• defend zero-rating for non-residents with foreign proof
• correct mixed-use hardware allocation
• create CRA-ready CPA-certified audit binder
• negotiate removal of penalties & interest

Learning insight: IT audits are won through data mapping, classification accuracy, and ITC reconstruction.


Common CRA Findings in IT Consulting Audits

• wrong GST/HST rate for out-of-province clients
• missing GST/HST on MSP retainers
• zero-rating denied for foreign client services
• ITCs denied due to invalid invoices
• subcontractor invoices with missing GST numbers
• imported software missing self-assessment
• personal-use devices claimed
• project billing inconsistent with timesheets
• incorrect classification of software resale vs consulting

Learning insight: 80% of adjustments come from place-of-supply errors + invalid ITCs.


Real-World Results

• A Montreal IT consultant avoided a $312,000 reassessment after Mackisen CPA rebuilt provincial rate logic and subcontractor documentation.
• A cloud-migration firm reversed a $184,000 ITC denial with complete SaaS & equipment records.
• A cybersecurity agency eliminated penalties by correcting foreign-client zero-rating.
• An MSP cleared CRA findings after reconciling monthly retainers with GST filings and software self-assessment.

Learning insight: CRA retreats when the firm presents clean, CPA-certified digital accounting.


SEO Optimization & Educational Value

Primary keywords: GST/HST IT consulting audit, CRA tech audit, software implementation GST rules, Mackisen CPA Montreal
Secondary keywords: ITC denial IT consultant, imported software GST, subcontractor GST audit, cloud service GST Canada

Learning insight: IT consulting GST rules are among the most searched audit topics — strong SEO opportunity.


Why Mackisen CPA Montreal

With 35+ years defending IT consultants, MSPs, software implementers, and cybersecurity firms, Mackisen CPA Montreal is Québec’s #1 authority for GST/HST IT audit defense.
We understand tech service classification, digital invoicing, subcontractor structures, and CRA methodology.

Learning insight: IT audits require deep tax expertise + understanding of tech operations + documentation precision — Mackisen delivers all three.


Call to Action

If CRA is auditing your IT consulting firm, tech support business, software implementation, SaaS expenses, or subcontractors, contact Mackisen CPA Montreal immediately:

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


Learning Conclusion:

A CRA GST/HST IT Consulting Audit tests client location, tax rates, consulting classification, imported software, subcontractor compliance, and ITC documentation.
Mackisen CPA Montreal ensures your tech business is fully defended and protected from costly reassessments.

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