For a CRA GST/HST audit, keep the original business records, record exactly what you searched and supplied, and preserve a copy of every response and receipt. A clear, contemporaneous record makes it easier to answer audit questions and support an objection or appeal. CRA’s authority to examine relevant records is described in its GST/HST Memorandum 15-1, current as of September 2026; the practical log below is a way to make your response traceable, not a CRA-prescribed form.
What to document during a GST/HST audit
CRA may inspect, audit, or examine relevant documents, property, or processes at reasonable times to administer or enforce GST/HST requirements. The records supporting your return can include sales and purchase invoices and other business-operation records. In practice, preserve the material that explains the reported transactions and tax treatment: ledgers, returns, receipts, contracts, bank statements, working papers, relevant emails, and CRA correspondence.
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CRA’s audit guidance says: “For an audit, you must make available to the auditor all of your relevant records (both paper and electronic) and supporting documents, and provide complete and timely explanations to the auditor’s questions.” Keep the underlying records as well as the explanations and documents you provide.
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Record the legal entity or registrant, GST/HST account, reporting periods, CRA audit reference, auditor or contact, date the first request arrived, stated deadlines, and the person coordinating the response. Retain the original CRA correspondence and, when available, envelope details or electronic receipt information.
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Translate each request into a search plan
For every request item, note the business question it relates to, likely source system or custodian, relevant reporting period, date range, search terms or filters, and planned output format. Distinguish records that are readily available from those that require a more complex search. CRA’s audit information-request policy describes an initial preliminary request period of up to 30 days for relevant books and records, but that policy figure is not a guaranteed deadline for every request. Use the date in your actual CRA request; promptly ask the auditor to clarify or extend it if needed, and keep a record of that exchange.
Keep a contemporaneous search log
There is no CRA-prescribed log format in the guidance cited here. A practical log helps show what was actually searched, what was found, and what was delivered. Include:
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- Date and time of each search, time zone, operator, and any witness or reviewer.
- CRA request number or reference, issue, reporting periods, and deadline.
- Source system, device or physical location, custodian, and whether the source was paper or electronic.
- Search terms, filters, date limits, and export method; note failed or unavailable systems.
- Records located, duplicates, records supplied, and the package or file name containing them.
- Missing items, the reason believed missing, who owns follow-up, and when the gap was reported to CRA.
- Any later correction or replacement, keeping the earlier version and explaining what changed.
If a search returns nothing, record the systems and terms you actually tried rather than making a broader claim that no record exists. Do not alter original business records to make them fit an audit response.
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CRA’s GST/HST books-and-records guidance requires records to be reliable, complete, supported by documents, and accessible to CRA officials in a usable form. Keep electronic records in their native format where possible, along with an intelligible review copy and a note describing any export or conversion. Do not let an unexplained spreadsheet export or scan replace the only source record.
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For paper documents, make legible scans when useful, retain originals where practicable, and link each copy to its source. Keep working copies of filed electronic returns and the invoices or documents supporting transaction totals and input tax credit claims. Use access controls and backups suited to the sensitivity and business needs of the records. CRA’s guidance covers electronic formats, imaging paper records, backups, and audit trails; it does not require buying a scanner.
Index everything supplied to CRA
For each response package, maintain an index that maps every CRA request item to the files or document ranges supplied. Include the relevant dates or period, source system or custodian, and any redactions or exclusions with the reason. Keep an exact copy of the package, the submission channel, date and time sent, delivery or portal confirmation, and any CRA acknowledgement.
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If you respond in stages, identify what remains outstanding and when you expect to provide it. A later replacement or correction should be separately identified and explained; preserve the original submission rather than silently overwriting it.
Keep dispute records and track the objection deadline
CRA’s general recordkeeping guidance says necessary records are generally kept for six years from the end of the relevant tax year. That ordinary period does not necessarily end the obligation for a dispute: CRA’s GST/HST recordkeeping memorandum says records pertaining to an objection or appeal must be kept until the proceeding and any appeal from it are finally disposed of. CRA’s records-to-keep guidance also says necessary records must be retained through resolution and expiry of any further appeal period where that is later than the usual period. Flag dispute-related material so routine destruction schedules do not remove it; check any CRA demand to retain records longer.
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The general GST/HST objection period is 90 days after the notice of assessment was sent, according to CRA’s May 2024 GST/HST Memorandum 31-0. Track that date separately from audit exchanges: discussions with CRA or an informal effort to resolve an issue should not be treated as filing an objection. Check the notice and current rules for the particular taxpayer and assessment. A late extension may be available in defined circumstances, but do not assume it applies.
Once an objection or appeal is in view, preserve the assessment, audit proposal and final letters, schedules, working papers received, records submitted, search logs, explanations, correspondence, and proof of delivery. For a threatened appeal, late objection, privilege question, or significant legal dispute, seek advice on the specific facts.
Build an objection from the record
Identify the assessment being challenged and set out the facts and reasons issue by issue. For each factual assertion, point to the source record and explain how it bears on the disputed GST/HST treatment. CRA’s objection memorandum says documents pertaining to the disputed issues are offered at the outset of the objection stage to help the person understand the assessment rationale.
Use the current CRA GST/HST objections page and follow the form or online-service instructions for the specific assessment. Do not rely on an old form reference without checking the current process: filing procedures can vary by context and change. CRA’s objection decision tool notes that new or previously requested information submitted with an objection may be sent back to the area that issued the assessment for another review. Keep a complete copy of the filed objection and its receipt confirmation.
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