Insight
Nov 28, 2025
Mackisen

CRA GST/HST Lock Installation, Locksmith Emergency Service & Key Cutting Contractor Audit — Montreal CPA Firm Near You: Defending Taxable Services, Parts, Emergency Calls, Subcontractors & ITCs

A CRA GST/HST Locksmith & Lock Installation Audit targets:
• mobile locksmiths
• emergency lockout service providers
• door lock installation technicians
• deadbolt & smart-lock installers
• key-cutting and rekeying specialists
• security lock upgrade contractors
• automotive lockout technicians
• subcontract locksmith helpers
Locksmith work is one of CRA’s fastest-growing audit categories because it combines:
• urgent emergency calls (often cash/e-transfer)
• taxable parts (locks, cylinders, keys, smart modules)
• mobile service routes
• subcontract helpers
• vehicle-heavy ITCs
• weak documentation for late-night/emergency work
Mackisen CPA Montreal specializes in defending locksmith businesses by correcting GST/HST treatment, rebuilding invoices, validating subcontractors, and reconstructing ITCs for tools, parts, travel, and vehicle usage.
Legal Foundation
Excise Tax Act
s.165 — ALL locksmith labour, installation, lockout service & key cutting are fully taxable
s.221 — locksmiths must collect GST/HST on all services
s.169 — ITCs allowed only with full documentary proof
s.141.01 — allocation rules for mobile tools & vehicles
Schedule IX — GST/HST based on location of the serviced property
s.123(1) — defines “repair,” “installation,” “service,” “labour”
CRA & Case Law
Lock installation = taxable
Lockout/emergency service = taxable
Key cutting = taxable
Rekeying cylinders = taxable
Royal Bank v. Canada — invoice defects eliminate ITCs
CGI v. Canada — place-of-supply determined by property location
Northwest Company Inc. — supplier invoices must meet statutory standards
Learning insight: No locksmith work is exempt — even unlocking a front door for 30 seconds requires GST/HST.
Why CRA Audits Locksmiths & Lock Installation Contractors
Revenue Risks
• GST/HST not charged on emergency lockouts
• cash/e-transfer micro-jobs not reported
• key-cutting fees not invoiced
• discounted late-night calls missing GST
• lock installation bundles not itemized
• deposits for smart-lock upgrades omitted
• automotive lockouts underreported
• QC/ON/Atlantic service-area jobs misrated
Subcontractor Risks
• locksmith helpers lacking GST registration
• cash labour with no invoices
• invalid GST/HST numbers
• misclassification (employee vs subcontractor)
• missing T4A filings for repeated subcontract work
ITC Risks
• missing receipts for:
– locks, deadbolts, cylinders
– smart-lock modules & keypads
– key-cutting blanks
– drill bits, bits, punches
– PPE & gloves
– OBD tools (vehicle lockout gear)
– fuel, tires, vehicle repairs
• imported tools not self-assessed for GST (s.218)
• personal-use tools included
• home garage/tool storage ITCs overclaimed
Operational Risks
• no job logs (lockouts rarely logged)
• WhatsApp/SMS bookings with no invoice
• emergency work not matched to deposits
• lock purchases inconsistent with revenue
• multi-site property manager clients underreported
• automotive lockouts not itemized
High-risk operators:
24/7 emergency locksmiths
mobile locksmith vans
automotive lockout specialists
subcontract-heavy lock installation teams
Learning insight: CRA flags locksmiths whose parts purchases far exceed declared service revenue.
CRA Locksmith & Lock Installation Audit Process
CRA requests:
– invoices (lockout, installation, rekeying, key cutting, parts)
– subcontractor invoices + GST numbers
– bank & e-transfer statements
– supplier receipts (locks, hardware, blanks, key machines)
– job logs / dispatch logs
– mileage logs
– ITC spreadsheets
– import receipts for tools / smart-lock modules
– T5018 summariesCRA tests:
• GST/HST applied to ALL services & parts
• subcontractor GST/HST compliance
• ITC documentation integrity
• logs → invoices → deposits → GST returns match
• imported tools self-assessed?
• material purchases vs revenue volume
• QC/ON border jobs taxed correctlyCRA issues Proposed Audit Adjustment.
Mackisen CPA prepares the full legal + documentary defense.
Learning insight: CRA rebuilds locksmith activity using part receipts, e-transfer logs & emergency-call patterns.
Mackisen CPA’s Locksmith Audit Defense Strategy
• create a Locksmith Tax Matrix (lockout, install, rekey, key cutting, parts, travel)
• rebuild GST/HST-compliant invoices
• validate subcontractor GST numbers
• reconstruct ITC binder (tools, locks, vehicle, PPE)
• reconcile job logs → invoices → deposits → GST filings
• defend part wastage (broken cylinders, test keys, drill-outs)
• correct GST/HST for cross-province jobs
• rebuild imported-tool self-assessment entries
• prepare a CPA-certified CRA audit binder
• negotiate removal of penalties & arrears
Learning insight: Locksmith audits are won with job-by-job logs, part reconciliation & subcontractor compliance.
Common CRA Findings in Locksmith Audits
• GST/HST not charged on emergency lockouts
• subcontractor invoices missing GST
• ITCs denied for missing receipts
• imported tools missing self-assessment
• bank deposits > reported revenue
• lock purchases inconsistent with declared jobs
• travel fees untaxed
• automotive lockouts unreported
Learning insight: CRA’s top assumption: “You bought more locks than you installed on invoices.”
Real-World Results
• A 24/7 emergency locksmith avoided a $189,000 reassessment after Mackisen CPA reconstructed call logs & parts usage.
• A mobile locksmith reversed a $121,000 ITC denial with complete tool & lock receipts.
• A smart-lock installer eliminated penalties by correcting GST/HST on parts + labour.
• An automotive lockout specialist cleared CRA findings via deposit → invoice → log reconciliation.
Learning insight: Detailed job logs immediately weaken CRA’s position.
SEO Optimization & Educational Value
Primary keywords: GST/HST locksmith audit, CRA lock installation audit, taxable lockout service Canada, Mackisen CPA Montreal
Secondary keywords: key-cutting GST, locksmith ITC denial, subcontract locksmith audit, imported lock tools GST
Learning insight: Locksmith GST compliance is a major SEO theme due to cash-based emergency work.
Why Mackisen CPA Montreal
With 35+ years defending locksmiths, security hardware installers & mobile lockout techs, Mackisen CPA Montreal is Québec’s #1 authority in GST/HST lock-service audits.
We understand emergency workflow, part usage patterns, subcontractor behaviour & CRA audit methodology deeply.
Learning insight: Locksmith audits require tight part-tracking, subcontractor validation & GST discipline — all strengths of Mackisen CPA.
Call to Action
If CRA is auditing your lock installation, emergency lockout, rekeying, or key-cutting business, contact Mackisen CPA Montreal immediately:
📞 514-276-0808
📧 info@mackisen.com
🌐 mackisen.com
Learning Conclusion:
A CRA GST/HST Locksmith Audit tests taxable labour, parts documentation, subcontractor GST compliance, ITC proof & revenue reconciliation.
Mackisen CPA Montreal ensures full audit protection.

