Insight
Nov 28, 2025
Mackisen

CRA GST/HST Photographer Assistant, Second Shooter & Creative Subcontractor Audit — Montreal CPA Firm Near You: Defending Taxable Labour, Subcontractor Compliance, Travel Fees & ITCs

A CRA GST/HST Photographer Assistant & Second Shooter Audit targets:
• second shooters
• photographer assistants
• lighting assistants
• behind-the-scenes (BTS) shooters
• freelance editors hired by photographers
• creative subcontractors in weddings, events & commercial shoots
• studio assistants on invoice
• travelling assistants on multi-day shoots
• assistant-only creative labour
This is a high-risk CRA category because subcontractor assistants often:
• fail to charge GST/HST
• have invalid GST numbers
• are paid in cash/e-transfer
• misclassify themselves as “not required to charge GST”
• provide incomplete invoices
• lack proper ITC documentation
Mackisen CPA Montreal specializes in protecting photographers, studios, and creative subcontractors in CRA audits by validating GST/HST registration, reconstructing invoices, and defending business expenses.
Legal Foundation
Excise Tax Act
s.165 — ALL creative labour (shooting, assisting, editing, lighting, BTS) is fully taxable
s.221 — subcontractors must charge GST/HST if registered
s.169 — ITCs allowed only with complete documentary proof
s.141.01 — mixed-use allocation (equipment, travel, software)
Schedule IX — GST/HST based on service location
s.123(1) — “service,” “subcontractor,” “digital service,” “intangible supply”
Case Law & CRA Policy
Creative labour = taxable
Subcontractor invoices MUST meet GST statutory criteria
Editing & retouching = taxable digital service
Travel/time fees = taxable
Royal Bank v. Canada — missing details = no ITC
Northwest Company Inc. — supplier-invoice precision required
Learning insight: ALL assistant, second-shooter, lighting, editing, and creative subcontract services MUST include GST/HST when the subcontractor is registered.
Why CRA Audits Photographer Assistants & Second Shooters
Revenue Risks
• GST/HST not charged on assistant labour
• travel/time fees missing GST
• second shooters not invoicing correctly
• e-transfer payments unreported
• editing fees treated as exempt (incorrect)
• multi-day wedding/event labour not taxed properly
• out-of-province shoots misrated
• cash jobs not on invoices
Subcontractor Risks
• assistants not registered for GST when required
• invalid GST numbers
• invoices missing legal requirements
• assistant treated as employee (T4A exposure)
• split-fee arrangements undocumented
ITC Risks
• missing receipts for:
– memory cards, batteries
– travel (mileage, fuel, hotels)
– props, lighting, stands
– editing software (Adobe, Capture One)
– camera gear rentals
• imported software/equipment missing s.218 self-assessment
• personal-use equipment claimed as business
• home-office/studio expenses overstated
Operational Risks
• second-shooter logs not matching lead photographer invoices
• assistants not issuing invoices
• mileage not documented
• booking calendars inconsistent with payments
• unclear division between taxable & non-taxable deliverables (ALL taxable in this category)
High-risk operators:
wedding second shooters
commercial BTS shooters
corporate event assistants
freelance editors & retouchers
studio assistants paid as subcontractors
Learning insight: CRA assumes missing GST, underreported subcontractor income, and invalid ITCs.
CRA Creative Subcontractor Audit Process
CRA requests:
– invoices issued to primary photographers
– subcontractor GST numbers
– bank & e-transfer records
– mileage logs & travel costs
– job logs / shoot calendars
– equipment/software receipts
– ITC spreadsheets
– editing export logs or project files
– imported gear receiptsCRA tests:
• whether GST/HST was charged correctly
• subcontractor GST registration compliance
• ITC documentation & eligibility
• invoice → deposit → GST return consistency
• personal vs business equipment
• provincial GST/HST logic for out-of-province shoots
• imported-software self-assessmentCRA issues a Proposed Audit Adjustment.
Mackisen CPA builds a complete legal + documentary defense.
Learning insight: CRA reconstructs revenue by comparing shoot logs, contracts, deposits and transfer histories.
Mackisen CPA’s Subcontractor Audit Defense Strategy
• build a Creative Labour Tax Matrix (shooting, assisting, editing, travel)
• reconstruct compliant invoices for past jobs
• validate GST registration + correct retroactive GST treatment if needed
• rebuild ITC binder for equipment, travel & software
• correct GST/HST on out-of-province shoots
• reconcile logs → invoices → deposits → GST filings
• defend travel ITCs with mileage logs & receipts
• reconstruct imported-software self-assessment
• prepare CPA-certified audit binder
• negotiate elimination of penalties & interest
Learning insight: Assistants win audits with complete logs + proper GST registration + ITC discipline.
Common CRA Findings in Assistant/Second-Shooter Audits
• GST/HST not charged on assistant labour
• missing invoices
• invalid subcontractor GST numbers
• ITCs denied due to missing receipts
• personal gear included in business ITCs
• multi-province shoots misrated
• bank deposits > reported revenue
• editing fees miscoded
Learning insight: Almost all reassessments are due to invoice defects + missing ITCs + underreported income.
Real-World Results
• A wedding second shooter avoided a $94,000 reassessment after Mackisen CPA rebuilt invoices & travel logs.
• A commercial assistant reversed a $61,000 ITC denial through complete equipment receipts & software compliance.
• A freelance editor eliminated penalties by correcting GST logic on digital deliverables.
• A multi-assistant studio cleared CRA findings via precise deposit→invoice→GST reconciliation.
Learning insight: CRA backs down when shown CPA-organized, shoot-by-shoot evidence.
SEO Optimization & Educational Value
Primary keywords: GST/HST second shooter audit, CRA creative subcontractor audit, photographer assistant GST rules Canada, Mackisen CPA Montreal
Secondary keywords: editing service GST, subcontractor GST compliance, creative ITC denial, mobile photography assistant GST
Learning insight: Subcontractor-creative audits generate strong SEO traffic due to confusion around GST thresholds and invoice rules.
Why Mackisen CPA Montreal
With 35+ years defending photographers, creative subcontractors, second shooters, and assistants, Mackisen CPA Montreal is Québec’s top authority for GST/HST creative-industry audits.
We understand subcontractor structures, digital deliverables, out-of-province GST/HST rules, and CRA audit methodology at expert level.
Learning insight: These audits require invoice precision, subcontractor compliance, and ITC rigor — all strengths of Mackisen CPA.
Call to Action
If CRA is auditing your assistant work, second-shooter contracts, editing subcontracting, or creative-labour GST filings, contact Mackisen CPA Montreal immediately:
📞 514-276-0808
📧 info@mackisen.com
🌐 mackisen.com
Learning Conclusion:
A CRA GST/HST Creative Subcontractor Audit tests taxable labour, subcontractor GST compliance, ITC documentation, digital-service GST rules & provincial rate accuracy.
Mackisen CPA Montreal ensures full protection from reassessments.

