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 VIIzero-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

  1. 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 records

  2. CRA 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 classification

  3. CRA issues a Proposed Reassessment

  4. 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.

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