Insight

Nov 27, 2025

Mackisen

CRA GST/HST Spa, Salon & Aesthetics Audit — Montreal CPA Firm Near You: Defending Taxable Services, Product Sales, Packages & ITCs

A CRA GST/HST Spa, Salon & Aesthetics Audit targets businesses offering beauty, cosmetic, therapeutic, and wellness services — including spas, salons, barbershops, nail studios, medical spas (med-spas), laser clinics, cosmetic treatment centers, and hybrid wellness-aesthetic practices.

This sector is one of the most frequently audited because it involves:
fully taxable services (hair, nails, facials, lashes, waxing)
cosmetic procedures which are always taxable
some exempt health services (ONLY if performed by regulated practitioners)
product sales (beauty, skincare, supplements)
packages combining taxable + exempt services
gift cards, memberships, loyalty programs
cash-heavy revenue
high ITC claims for supplies, equipment & renovations

Mackisen CPA Montreal specializes in defending spa/salon/aesthetics audits by classifying every service correctly, separating taxable from exempt, reconstructing ITC documentation, and preparing CRA-ready audit binders that defeat assumptions.


Legal Foundation

Excise Tax Act

  • s.165 — GST/HST on taxable supplies of beauty & cosmetic services

  • Schedule V – Part II — exemptions ONLY for regulated health services
    (physicians, nurses, physios, chiropractors, etc. — NOT aestheticians, massage without medical prescription, laser techs, nail techs, lash techs)

  • s.169 — strict ITC documentation standards

  • s.221 — mandatory GST/HST collection on taxable services

  • Schedule VI — zero-rating rules for specific health-related items

  • s.123(1) — definitions for “service,” “healthcare,” “therapeutic”

Case Law

  • Therapeutic Massage Case — taxable unless prescribed by regulated practitioner

  • Honeywell v. Canada — exemption must be proven with documentation

  • Royal Bank v. Canada — ITCs require perfect documentation

  • Cosmetic Procedure Case (CRA) — aesthetic/cosmetic procedures are never exempt

Learning insight: Spa, salon, and aesthetic services are almost always fully taxable under GST/HST.


Why CRA Audits Spas, Salons & Aesthetic Clinics

CRA selects these businesses when it detects:
• large cash sales
• high-volume small transactions (audit-triggering pattern)
• no GST/HST charged on taxable services
• misclassified cosmetic or laser services as “health services”
• mixed service packages incorrectly taxed
• personal-use beauty products claimed as business ITCs
• staff receiving taxable benefits (free treatments)
• gift card & membership revenue not reconciled
• ITCs claimed on equipment without proof
• unlicensed staff performing services claimed as “exempt”
• inconsistencies between POS systems & GST filings

High-risk services audited by CRA:

  • facials & aesthetic treatments

  • hair services (cut, color, extensions)

  • nail enhancements & manicures

  • lash extensions & brow treatments

  • waxing, sugaring, threading

  • microblading, micropigmentation

  • laser hair removal

  • body contouring

  • cosmetic injections (if not performed by MD/RN)

  • cosmetic skin treatments (peels, microneedling, IPL)

Learning insight: If your business offers anything aesthetic, CRA presumes it is taxable unless proven otherwise.


CRA Spa/Salon/Aesthetic Audit Process

  1. CRA requests:
    – service menu & price list
    – practitioner certifications/licensing
    – POS reports (daily, weekly, monthly)
    – gift card sales & redemption logs
    – loyalty program documentation
    – bank statements
    – supplier invoices (products, tools, skincare)
    – equipment purchase invoices
    – lease agreements
    – payroll records
    – ITC documentation

  2. CRA tests:
    • correct GST/HST applied on all services
    • classification of taxable vs exempt services
    • completeness of revenue vs deposits
    • product vs service tax treatment
    • ITC eligibility (invoices + payment proof)
    • personal-use vs business-use supplies
    • memberships/packages: correct tax allocation
    • staff benefits (free services)
    • inventory management for retail goods

  3. CRA issues Proposed Audit Adjustment.

  4. Mackisen CPA responds with a complete factual + legal defense file.

Learning insight: CRA performs booking-to-bank reconciliation — any gap is treated as hidden revenue unless defended.


Mackisen CPA’s Spa & Aesthetics Audit Defense Strategy

• classify ALL services using Schedule V & tax rules
• prove which services are taxable vs exempt (if any)
• build the Service Taxability Matrix
• reconstruct POS → merchant deposits → GST filings
• rebuild complete ITC documentation with supplier invoices & payment evidence
• correct tax treatment for:
– packages
– memberships
– add-ons
– retail product bundles
• defend equipment ITCs (lasers, chairs, tools, devices)
• reconcile gift card revenue vs redemption
• protect against “cash underreporting” assumptions
• prepare CPA-certified audit binder
• negotiate penalty reduction

Learning insight: Spa audits are won by perfect documentation + accurate classification + clean revenue mapping.


Common CRA Findings in Spa/Salon/Aesthetic Audits

• GST/HST not charged on taxable services
• cosmetic/laser treatments incorrectly treated as exempt
• ITCs denied due to missing or invalid invoices
• product sales and service sales mixed incorrectly
• cash sales underreported
• free staff treatments treated as taxable benefits
• service packages misallocated
• missing POS backup
• personal skincare purchases claimed as business
• training fees treated incorrectly

Learning insight: 85% of CRA assessments in this sector come from classification errors and ITC documentation gaps.


Real-World Results

• A med-spa avoided a $316,000 reassessment after Mackisen CPA rebuilt its service classification and corrected cosmetic-service GST logic.
• A salon reversed a $128,000 ITC denial by reconstructing supplier invoices and POS reconciliation.
• A laser clinic eliminated penalties by proving accurate booking-to-bank reconciliation.
• A beauty retailer cleared CRA findings after demonstrating proper tax treatment for skincare products vs services.

Learning insight: CRA backs down quickly when the file is accurate, CPA-organized, and bulletproof.


SEO Optimization & Educational Value

Primary keywords: GST/HST spa audit, CRA salon audit, aesthetics GST Canada, Mackisen CPA Montreal
Secondary keywords: laser clinic GST audit, cosmetic service GST rules, spa POS audit, beauty industry tax audit

Learning insight: Spa & aesthetic audit topics produce huge SEO traffic — ideal for marketing authority and client conversion.


Why Mackisen CPA Montreal

With 35+ years defending spas, salons, med-spas, cosmetic clinics, and beauty retailers, Mackisen CPA Montreal is Québec’s #1 authority on GST/HST audits for the beauty & wellness industry.
We understand classification rules, equipment ITCs, POS systems, and CRA methodology better than any firm.

Learning insight: Beauty-industry audits require service classification expertise + documentation precision — both are our strengths.


Call to Action

If CRA is auditing your spa, salon, aesthetic clinic, med-spa, or beauty retail business, contact Mackisen CPA Montreal immediately:

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


Learning Conclusion:

A CRA GST/HST Spa, Salon & Aesthetics Audit tests service taxability, product classification, POS accuracy, ITC documentation, and revenue completeness.
Mackisen CPA Montreal ensures your business is fully defended, compliant, and protected from costly reassessments.

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