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
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 listsCRA 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 periodsCRA issues Proposed Audit Adjustment.
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.

