CRA GST/HST Multi-Province Business Audit — Montreal CPA Firm Near You: Defending Tax Rates, Provincial Allocation, Remote Operations & Cross-Border Clients

A CRA GST/HST Multi-Province Business Audit targets businesses operating in two or more provinces, whether through remote service delivery, traveling employees, interprovincial shipping, online operations, or physical branch locations.
This is one of the most complex and frequently misunderstood GST/HST audit areas because CRA aggressively examines place-of-supply rules, cross-province invoicing, ITC allocations, and intercompany transactions.

Multi-province audits affect:
• consultants & professional services
• construction companies
• real estate teams
• transportation/logistics
• e-commerce sellers
• software and digital companies
• staffing agencies
• manufacturers & distributors
• franchisors & multi-location businesses
• healthcare & wellness service providers

Mackisen CPA Montreal specializes in defending multi-province audits by reconstructing provincial tax mapping, validating ITCs, correcting rate errors, and producing CPA-certified audit binders that remove CRA assumptions.

Legal Foundation

Excise Tax Act

• Schedule IX — the core rulebook for place-of-supply

• s.165 — GST/HST on taxable supplies

• s.221 — requirement to collect & remit GST/HST

• s.169 — ITC rules and documentation requirements

• s.141.01 — expense allocation rules for multi-province businesses

• s.240 — mandatory GST/HST registration thresholds

Provincial HST Rates

• 15% — NS, NL, NB, PE

• 13% — ON

• 5% — QC, MB, SK, AB, BC, Territories (GST only)

Case Law

• City of Calgary v. Canada — consumption determines tax jurisdiction

• Canadian Medical Protective Association — supply location matters more than contract wording

• Royal Bank v. Canada — ITCs require flawless documentation

Learning insight: The province of the customer—not the supplier—is usually the deciding factor for GST/HST.

Why CRA Audits Multi-Province Businesses

CRA flags these businesses when it detects:
• invoices applying wrong provincial tax rates
• services delivered remotely but taxed incorrectly
• interprovincial travel with unclear GST/HST treatment
• goods shipped to one province but billed to another
• digital services consumed in multiple jurisdictions
• subcontractors in other provinces
• large ITCs claimed across provinces
• inconsistent registration status (GST vs HST provinces)
• e-commerce transactions not matching GST filings
• payroll or consulting work done across provincial borders

High-risk sectors:

• consulting firms

• IT & SaaS companies

• real estate teams

• staffing & temp agencies

• construction & trades

• logistics & transportation

• e-commerce & wholesale

• franchisors & multi-location operators

Learning insight: CRA assumes a business is applying wrong GST/HST rates unless documented otherwise.

CRA Multi-Province Audit Process

1. CRA requests:
   – client lists with addresses
   – invoicing by province
   – contracts & service agreements
   – shipping documentation (FOB, bill of lading)
   – travel logs & remote-work details
   – time-tracking or project records
   – subcontractor invoices
   – ITC documentation
   – financial statements
   – GST/HST filings for all periods

2. CRA tests:
   • correct tax rate applied per province
   • supply location (service or good)
   • delivery vs billing location
   • digital consumption location
   • goods shipped vs services consumed
   • subcontractor compliance
   • ITC allocations across provincial operations
   • registration obligations in each province

3. CRA issues Proposed Audit Adjustment.

4. Mackisen CPA prepares a complete legal & documentary defense.

Learning insight: CRA often misinterprets where the supply “occurred” — the CPA must correct their assumptions.

Mackisen CPA’s Multi-Province Audit Defense Strategy

• rebuild a Provincial Tax Rate Matrix for every client & invoice
• classify each transaction as:
– supply of service
– supply of good
– digital/intangible
– hybrid supply
• prepare Supply-Location Maps for remote or hybrid businesses
• reconstruct ITC documentation by province
• validate subcontractor GST/HST numbers across jurisdictions
• reconcile interprovincial shipments with GST/HST rules
• defend zero-rating for non-resident clients (if applicable)
• correct errors in historical returns
• prepare CPA-certified audit binder
• negotiate penalty reductions

Learning insight: Multi-province audits are won by demonstrating precise, evidence-based tax logic—not by theory.

Common CRA Findings in Multi-Province Audits

• charging 5% GST instead of 13%/15% HST
• applying HST when only 5% GST should apply
• services consumed in ON or Atlantic provinces taxed incorrectly
• ITCs denied for lack of supporting invoices
• shipping documents missing → place-of-supply misinterpreted
• subcontractor expenses invalid (missing GST numbers)
• payroll/travel costs misallocated
• digital products misclassified
• combined consulting + SaaS supplies taxed incorrectly
• business operating in QC but serving ON → GST/HST rate wrong

Learning insight: The most frequent audit failures involve place-of-supply errors and incomplete ITC documentation.

Real-World Results

• A national consulting firm avoided a $690,000 reassessment when Mackisen CPA rebuilt its provincial tax map.
• A SaaS + service hybrid company reversed a $310,000 ITC denial by proving consumption location and ITC eligibility.
• A construction group working in QC/ON/NS eliminated penalties after correcting multi-province invoicing.
• A real estate team operating in QC + ON cleared CRA findings when we reconciled commissions with correct tax rates.

Learning insight: CRA withdraws when presented with clear, documented GST/HST logic across provinces.

SEO Optimization & Educational Value

Primary keywords: GST/HST multi-province audit, CRA place of supply audit, Mackisen CPA Montreal, GST audit interprovincial
Secondary keywords: HST rate errors, GST/HST provincial tax matrix, CRA cross-province audit, remote service GST rules

Learning insight: Multi-province GST issues are among the highest-searched topics for Canadian businesses.

Why Mackisen CPA Montreal

With 35+ years defending multi-province businesses, Mackisen CPA Montreal is Québec’s #1 authority on cross-province GST/HST compliance.
We understand place-of-supply law, provincial rate rules, remote service taxation, and CRA audit behavior better than any firm.

Learning insight: Multi-province audits are won through mapping + evidence + defensible tax logic — all strengths of Mackisen CPA.

Call to Action

If CRA is auditing your multi-province invoicing, ITCs, tax rates, or cross-border activities, contact Mackisen CPA Montreal immediately:

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

Learning Conclusion:

A CRA GST/HST Multi-Province Business Audit tests provincial rate accuracy, supply location, documentation, ITCs, and subcontractor compliance.
Mackisen CPA Montreal ensures your cross-province operations are fully defended and protected from costly reassessments.