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

  1. 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 receipts

  2. CRA 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-assessment

  3. CRA issues a Proposed Audit Adjustment.

  4. 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.

All-in-One Accounting, Tax, Audit, Legal & Financing Solutions for Your Business

Are you ready to feel the difference?

Have questions or need expert accounting assistance? We're here to help.

Let’s Stay In Touch

Follow us on LinkedIn for updates, tips, and insights into the world of accounting.

Terms & conditionsPrivacy PolicyService PolicyCookie Policy

@ Copyright Mackisen Consultation Inc. 2010 – 2024. •  All Rights Reserved.

© 1990-2024. See Terms of Use for more information.

Mackisen refers to Mackisen Global Limited (“MGL”) and its global network of member firms and associated entities collectively constituting the “Mackisen organization.” MGL, alternatively known as “Mackisen Global,” operates as distinct and independent legal entities in conjunction with its member firms and related entities. These entities function autonomously, lacking the legal authority to obligate or bind each other in transactions with third parties. Each MGL member firm and its associated entity assumes exclusive legal accountability for its actions and oversights, explicitly disclaiming any responsibility or liability for other entities within the Mackisen Organization. It is of legal significance to underscore that MGL itself refrains from rendering services to clients.