Insight

Nov 28, 2025

Mackisen

. CRA GST/HST Pest Prevention, Commercial Disinfection & Sanitization Audit — Montreal CPA Firm Near You: Defending Taxable Services, Chemical ITCs, Subcontractors & Recurring Contracts

A CRA GST/HST Pest Prevention, Commercial Disinfection & Sanitization Audit targets:

• commercial disinfecting companies
• sanitization crews (offices, restaurants, clinics)
• antimicrobial fogging services
• disinfection of gyms, daycares & retail businesses
• pest-prevention maintenance visits
• rodent-entry sealing (preventive services)
• recurring disinfecting contracts (weekly/monthly)
• subcontracted sanitation workers
• emergency outbreak response teams

This sector is heavily audited because disinfecting and pest-prevention services are 100% taxable, involve chemical purchases, recurring contracts, subcontractor crews, and high volumes of cash/e-transfer transactions. CRA scrutinizes the entire workflow: chemicals → crew logs → invoices → deposits → GST returns.

Mackisen CPA Montreal specializes in defending cleaning/disinfection firms through GST/HST accuracy, subcontractor verification, chemical-use ITC documentation, and audit-ready recordkeeping.


Legal Foundation

Excise Tax Act

  • s.165 — ALL disinfecting, sanitizing, pest-prevention & microbial fogging services are fully taxable

  • s.221 — GST/HST must be charged and collected from all clients

  • s.169 — ITC claims require complete supporting documentation

  • s.141.01 — mixed-use allocation for equipment & chemicals

  • Schedule IX — GST/HST depends on the service location (QC/ON/Atlantic)

  • s.123(1) — “cleaning,” “sanitizing,” “maintenance,” “real-property service”

Case Law & CRA Rulings

  • Disinfection & sanitization = taxable (no exemption)

  • Preventive rodent-barrier services = taxable

  • Fogging, antiviral treatments & surface-spray services = taxable

  • Royal Bank v. Canada — ITCs denied if invoices incomplete

  • Northwest Company Inc. — supplier documentation must meet legal requirements

Learning insight: Neither disinfection nor pest-prevention services fall under any health exemption — 100% taxable at all times.


Why CRA Audits Sanitization & Prevention Contractors

Revenue Risks

• GST/HST not charged on disinfection services
• multi-visit prevention contracts not taxed correctly
• emergency outbreak treatments paid in cash, unreported
• chemical-application fees incorrectly coded
• travel/special-equipment fees missing GST
• corporate contracts not aligned with GST filing periods
• inconsistent recurring-contract revenue
• e-transfer payments underreported

Subcontractor Risks

• subcontracted sanitization techs not GST-registered
• helpers paid cash without invoices
• T4A non-compliance for contract workers
• invalid GST numbers on subcontractor invoices
• no documentation for PPE/chemical crew members

ITC Risks

• missing invoices for:
– disinfectants, antiviral sprays
– electrostatic sprayers & foggers
– PPE (suits, masks, gloves)
– HEPA filters, vacuums
– chemical meters & pumps
– vehicle/travel expenses
• imported foggers/sprayers missing s.218 self-assessment
• personal-use supplies included in business ITCs
• chemical purchases not tied to jobs

Operational Risks

• no disinfecting logs or chemical-use records
• commercial jobs not invoiced individually
• corporate cleaning bundles not itemized
• multiple visits per month missing from invoices
• emergency after-hours jobs not declared
• site-entry forms not matching billing

High-risk operators:

  • office-sanitizing firms

  • restaurant/food-service disinfectors

  • medical/clinic sanitation contractors

  • preventive rodent-entry sealing teams

  • commercial building sanitization crews

Learning insight: CRA expects chemical-use logs + subcontractor documentation + deposit reconciliation.


CRA Disinfection & Prevention Audit Process

  1. CRA requests:
    – invoices (disinfection, fogging, prevention, travel)
    – subcontractor invoices + GST numbers
    – job logs (date, time, duration, location)
    – chemical purchase invoices
    – fogging & sprayer-equipment receipts
    – PPE & safety-gear receipts
    – bank & e-transfer statements
    – ITC spreadsheets
    – import documentation
    – recurring contract lists

  2. CRA tests:
    • GST/HST charged on all visits & treatments
    • subcontractor compliance
    • ITC documentation & proof of payment
    • chemical-use volume → job volume → revenue consistency
    • imported foggers/sprayers → self-assessment
    • rate accuracy (QC vs ON vs Atlantic)
    • recurring contract timing vs GST periods

  3. CRA issues Proposed Audit Adjustment.

  4. Mackisen CPA prepares a full legal + documentary defense.

Learning insight: CRA rebuilds operations using chemical purchases, job logs & deposit trails.


Mackisen CPA’s Sanitization Audit Defense Strategy

• build a Sanitization Tax Matrix (fogging, prevention, disinfection, travel, add-ons)
• rebuild all invoices to include GST/HST correctly
• validate subcontractor GST registrations
• reconstruct ITC binder (chemicals, foggers, PPE, vehicles)
• reconcile job logs → invoices → deposits → GST returns
• defend imported-equipment ITCs with proper self-assessment
• correct GST/HST rate for interprovincial commercial contracts
• prepare a CRA-certified CPA audit binder
• negotiate removal of penalties & interest

Learning insight: Disinfection audits are won through chemical reconciliation + subcontractor control + accurate GST classification.


Common CRA Findings in Disinfection & Prevention Audits

• GST/HST not charged on one-time or recurring visits
• subcontractor invoices invalid or missing GST numbers
• ITCs denied for incomplete receipts
• chemical purchases not tied to service logs
• imported foggers/tools missing GST
• bank deposits > reported revenue
• personal-use PPE & supplies claimed
• rate errors for multi-province contracts

Learning insight: CRA’s largest reassessments result from invoice defects, missing chemical ITCs & subcontractor issues.


Real-World Results

• A commercial sanitation firm avoided a $216,000 reassessment after Mackisen CPA rebuilt chemical-use logs & subcontractor documentation.
• A restaurant-sanitizing contractor reversed a $147,000 ITC denial with complete PPE, software & chemical receipts.
• A preventive sealing service eliminated penalties after correcting GST on recurring monthly visits.
• An industrial disinfection team cleared CRA findings with deposit→invoice→log reconciliation.

Learning insight: CRA backs down when you present CPA-organized, evidence-driven job records.


SEO Optimization & Educational Value

Primary keywords: GST/HST disinfection audit, CRA sanitization audit, taxable cleaning services Canada, Mackisen CPA Montreal
Secondary keywords: chemical ITC denial, subcontractor sanitization audit, fogging GST/HST rules, preventive pest sealing GST

Learning insight: Sanitization & disinfection audits are high-traffic SEO topics, especially post-pandemic.


Why Mackisen CPA Montreal

With 35+ years defending disinfecting, sanitization & preventive-pest contractors, Mackisen CPA Montreal is Québec’s top authority in GST/HST audits for this expanding sector.
We understand chemical usage, recurring contracts, subcontractor networks & CRA methodology thoroughly.

Learning insight: These audits require precise job tracking, chemical reconciliation & ITC rigor — all strengths of Mackisen CPA.


Call to Action

If CRA is auditing your disinfection, sanitization, preventive pest-entry sealing, or commercial cleaning business, contact Mackisen CPA Montreal immediately:

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


Learning Conclusion:

A CRA GST/HST Disinfection & Preventive-Maintenance Audit tests taxable labour, chemical documentation, subcontractor compliance, ITC legitimacy & revenue reconciliation.
Mackisen CPA Montreal ensures full audit protection.

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