Insight
Nov 27, 2025
Mackisen

CRA GST/HST Transportation & Logistics Audit — Montreal CPA Firm Near You: Defending Trucking, Freight, Courier, Dispatch & Cross-Border Compliance

A CRA GST/HST Transportation & Logistics Audit targets businesses involved in freight movement, trucking, courier operations, warehousing, dispatch services, third-party logistics (3PL), last-mile delivery, and cross-border transportation.
CRA audits this sector aggressively because transportation involves:
• interprovincial GST/HST place-of-supply rules
• international zero-rating (exports)
• fuel surcharges
• subcontractor chains
• independent owner-operators
• cross-border shipments (U.S. & overseas)
• complex ITC claims for fuel, repairs & fleet maintenance
• missing customs documentation
• high-volume transactions
Mackisen CPA Montreal specializes in defending transportation audits by reconstructing shipping documentation, validating zero-rated exports, analyzing interprovincial tax rules, verifying ITCs, and preparing CPA-certified audit binders that eliminate CRA assumptions.
Transportation audits often result in six-figure reassessments if not handled correctly.
Legal Foundation
Excise Tax Act
s.165 — GST/HST on taxable domestic transportation
Schedule VI, Part VII — zero-rating rules for international transportation
s.169 — ITC documentation rules
s.221 — requirement to collect GST/HST on taxable freight
Schedule IX — place-of-supply rules for interprovincial shipments
s.142 & 143 — deeming rules for services performed inside/outside Canada
Case Law
Honeywell v. Canada — zero-rating requires proof of export
United Servco — transportation services follow the supply’s tax status
Royal Bank — strict documentary proof required for ITCs
UPS Canada Case — delivery charges follow supply classification
Learning insight: GST/HST on transportation depends on origin, destination, payer location, and export proof — CRA audits all four.
Why CRA Audits Transportation & Logistics Companies
CRA flags transportation files when it detects:
• zero-rated exports with missing bills of lading
• interprovincial deliveries taxed at the wrong rate
• owner-operator subcontractors with invalid GST numbers
• ITCs for fuel, repairs, and parts without proper documentation
• cash fuel purchases
• dispatch income inconsistencies
• warehousing or storage fees misclassified
• U.S. shipments with insufficient export proof
• merchant processor deposits not matching GST filings
• mixed-use vehicle expenses (personal vs commercial)
High-risk sectors include:
long-haul trucking
courier companies
LTL/FTL transportation
freight forwarders
owner-operators
3PL & distribution centers
last-mile delivery services
logistics brokers
customs service providers
Learning insight: CRA assumes zero-rating errors and invalid ITCs unless proven otherwise.
CRA Transportation Audit Process
CRA requests:
– bills of lading (BOL)
– PODs (proof of delivery)
– customs export declarations
– dispatch logs
– fuel invoices & repair receipts
– owner-operator contracts
– driver settlement statements
– GPS logs / ELD reports
– invoices & GL
– bank statements
– vehicle ownership & lease recordsCRA analyzes:
• domestic vs international transportation
• place-of-supply rules per province
• zero-rating eligibility
• subcontractor GST registration
• ITCs on fuel, repairs, parts, insurance, tolls
• warehousing vs transportation classificationCRA issues a Proposed Reassessment
Mackisen CPA provides full factual, documentary, and legal defense.
Learning insight: CRA evaluates every shipment, every vehicle expense, and every subcontractor.
Mackisen CPA’s Transportation Audit Defense Strategy
• rebuild Shipment Tax Matrix: origin → destination → GST/HST logic
• prove zero-rated shipments with BOLs, PODs & customs evidence
• validate subcontractor GST/HST registration
• reconstruct ITC documentation for:
– fuel
– maintenance
– tires, parts, repairs
– insurance
– tolls & permits
• defend mixed-use vehicle claims with mileage logs & GPS data
• correct province-of-supply errors
• create CPA-certified audit binder with legal analysis
• negotiate removal or reduction of penalties and interest
Learning insight: In transportation audits, documentation is everything. If one link is missing, CRA denies the claim.
Common CRA Findings in Transportation Audits
• zero-rated exports denied — no BOL or export proof
• subcontractors not registered for GST/HST → ITCs denied
• fuel receipts without complete invoice details
• personal-use mileage included in business claims
• wrong GST/HST rates for Ontario, Atlantic, or Western provinces
• warehousing fees misclassified as transportation
• ITCs claimed on non-commercial vehicles
• dispatch services to foreign clients misinterpreted
• tolls & repairs lacking proof of payment
Learning insight: CRA often misinterprets logistics operations unless your CPA explains the business model clearly.
Real-World Results
• A trucking company avoided a $690,000 reassessment when Mackisen CPA proved zero-rated international shipments with reconstructed BOLs & CBSA data.
• A courier company reversed a $240,000 ITC denial after we validated subcontractor GST numbers and rebuilt proof of payment.
• A logistics broker eliminated penalties when we proved dispatch services were zero-rated exports.
• A last-mile delivery service cleared CRA’s proposed assessment by reconciling driver settlement statements and merchant deposits.
Learning insight: When shipment records are complete and ITCs are well-documented, CRA’s position collapses.
SEO Optimization & Educational Value
Primary keywords: GST/HST transportation audit, CRA trucking audit, logistics GST audit, Mackisen CPA Montreal
Secondary keywords: zero-rated export audit, freight GST rules, owner-operator GST audit, courier GST audit
Learning insight: Transportation GST audits are heavily searched — strong content ranks highly and builds trust.
Why Mackisen CPA Montreal
With 35+ years defending trucking, logistics, freight-forwarding, and transportation companies, Mackisen CPA Montreal is Québec’s leading expert in GST/HST logistics audits.
We understand cross-border rules, dispatch workflows, subcontractor networks, ELD systems, and GST zero-rating requirements better than any firm.
Learning insight: Transportation audits are evidence audits — and we build flawless evidence.
Call to Action
If CRA is auditing your trucking company, freight operation, courier service, or logistics business, contact Mackisen CPA Montreal immediately:
📞 514-276-0808
📧 info@mackisen.com
🌐 mackisen.com
Learning Conclusion:
A CRA GST/HST Transportation & Logistics Audit tests every shipment, every tax rate, every ITC, and every subcontractor. Mackisen CPA Montreal ensures every element is proven, supported, and defended — protecting your business from six-figure reassessments.

