CRA GST/QST Compliance Audit 2025 — Defend Your Business, Recover Denied Credits, and Prevent Heavy Penalties

A CRA or Revenu Québec GST/QST compliance audit can drain your business if you’re not prepared. In 2025, CRA and Revenu Québec have fully integrated digital audit systems that automatically cross-check your sales, purchases, and GST/QST filings against supplier data and industry averages. Even small discrepancies — like missing invoices or mismatched reporting — can trigger audits that deny Input Tax Credits (ITCs) and Input Tax Refunds (ITRs). These errors can lead to reassessments, frozen refunds, and tens of thousands in penalties. But with the right team, these audits can be resolved, reversed, and even turned to your advantage. At Mackisen CPA Auditors Montreal, we specialize in defending GST and QST audits for businesses across Canada. Our CPA auditors and tax lawyers examine every line of CRA and Revenu Québec’s findings, reconstruct accurate records, and build persuasive legal arguments to protect your rightfully claimed credits. We don’t let CRA or Revenu Québec decide your outcome — we take control of it.

Legal and Regulatory Framework

Excise Tax Act (Canada)

• Section 225: Defines taxpayer entitlement to Input Tax Credits (ITCs).

• Section 286: Requires maintaining complete GST/HST records for verification.

• Section 296: Grants CRA audit and reassessment authority, which can be challenged.

• Section 299: Protects taxpayers’ rights to object and appeal reassessments.
  Tax Administration Act (Quebec)
  Revenu Québec governs Input Tax Refunds (ITRs) for QST and can conduct joint audits with CRA. Mackisen prepares unified compliance files for both agencies to ensure full consistency and maximum defense.

Key Court Decisions

Les Entreprises XY v. The Queen (2020): CRA must evaluate legitimate ITCs and cannot deny them without sufficient evidence.
North Shore Power Group v. The Queen (2018): Late or missing invoices can still qualify for ITCs if valid business use is proven.
Bédard v. The Queen (2022): CRA’s automated audits can be challenged successfully with professional representation.
Guindon v. Canada (2015): CRA penalties may be waived under the Taxpayer Relief Program if reasonable care is shown.
These rulings confirm that CRA and Revenu Québec must respect due process — and taxpayers who act diligently can win.

Why CRA and Revenu Québec Conduct Compliance Audits

GST/QST compliance audits are designed to detect under-reporting, missed remittances, or overclaimed credits. Common 2025 triggers include:

• Frequent refund claims or high ITC/ITR ratios.

• Supplier registration or documentation errors.

• Discrepancies between CRA and Revenu Québec filings.

• Unfiled or amended returns.

• Industry sectors with high cash or subcontracting activity (construction, retail, manufacturing).
  CRA and Revenu Québec assume mistakes — Mackisen proves legitimate compliance.

Mackisen’s GST/QST Compliance Audit Defense Strategy

1. Audit Review: Examine CRA or Revenu Québec’s audit scope and identify procedural errors.

2. Record Reconstruction: Rebuild and reconcile invoices, supplier data, and accounting records.

3. Legal Defense Preparation: Prepare a unified response citing both federal and Quebec tax legislation.

4. Direct Representation: Handle all communications and audit meetings to protect your interests.

5. Relief and Appeal: File formal objections and Taxpayer Relief applications to reverse penalties and reclaim denied credits.
   Our audit defense ensures your rights are respected, your records are validated, and your business stays fully operational.

Real Client Experience

A Montreal importer was denied $136,000 in GST/QST credits due to missing supplier documentation. Mackisen reconstructed invoices, proved validity, and secured full credit recovery.
A Quebec retailer was assessed $82,000 in QST penalties for “incorrect filings.” Mackisen demonstrated clerical error, filed a relief request, and reduced the penalty to zero.

Common Questions

Can CRA and Revenu Québec audit at the same time? Yes — Mackisen coordinates both to ensure unified responses and consistent reporting.
Can CRA deny ITCs for missing invoices? Yes, but Mackisen can restore them with alternate documentation or reconstructed records.
How long does a compliance audit last? Usually 2–6 months, but early intervention shortens the timeline dramatically.
Can I appeal CRA and Revenu Québec audit results? Absolutely — Mackisen files formal objections and appeals for both agencies simultaneously.

Why Mackisen

At Mackisen CPA Auditors Montreal, we know the audit system from the inside out. Our combined accounting and legal expertise gives businesses the advantage they need to fight and win. We don’t just correct the audit — we correct the system’s bias against honest taxpayers. We act fast, argue strategically, and deliver results that protect your business long after the audit ends. When CRA and Revenu Québec audit your compliance, Mackisen audits their conclusions.
Call Mackisen CPA Auditors Montreal today for your 2025 GST/QST Compliance Audit Consultation. The first meeting is free, and your protection starts immediately.