Compliance
Compliance Spotlight: CRA’s Focus Areas & What Businesses Should Know in 2026-27
The CRA is increasing enforcement and streamlining compliance—this article outlines where the risks lie and what businesses should do to stay ahead.
By NomadicTax Research Team • 5-8 min read • April 12, 2026
## Compliance Trends in 2026-27
In its **2026-27 Departmental Plan**, the Canada Revenue Agency (CRA) lays out major priorities, including tightening compliance, particularly around GST/HST refund schemes and aggressive tax planning. ([canada.ca](https://www.canada.ca/en/revenue-agency/corporate/about-canada-revenue-agency-cra/departmental-plan/2026-27-cra-departmental-plan.html?utm_source=openai)) According to the plan, notable strategic focuses include:
- Combating high-risk sectors for tax evasion and GST/HST fraud (including carousel schemes). ([canada.ca](https://www.canada.ca/en/revenue-agency/corporate/about-canada-revenue-agency-cra/departmental-plan/2026-27-cra-departmental-plan.html?utm_source=openai))
- Using data analytics and international co-operation to uncover non-compliance. ([canada.ca](https://www.canada.ca/en/revenue-agency/corporate/about-canada-revenue-agency-cra/departmental-plan/2026-27-cra-departmental-plan.html?utm_source=openai))
- Improving processes for SR&ED claims and making technical eligibility more transparent via an elective pre-claim approval, aimed at cutting review time from **180 days to 90 days** for certain claims. ([canada.ca](https://www.canada.ca/en/revenue-agency/corporate/about-canada-revenue-agency-cra/departmental-plan/2026-27-cra-departmental-plan.html?utm_source=openai))
## Business Exposure Points
Here are areas where Canadian businesses are being watched closely:
- **GST/HST refund schemes**: Businesses claiming large or sudden input tax credit refunds without corresponding output tax are under greater scrutiny. Ensure documentation is solid and claims are defensible. ([canada.ca](https://www.canada.ca/en/revenue-agency/corporate/about-canada-revenue-agency-cra/departmental-plan/2026-27-cra-departmental-plan.html?utm_source=openai))
- **Aggressive inter-company or affiliate transactions**: Transfer pricing, interposed corporations, and deferral of corporate income via investment income are flagged. The draft legislative proposals from Finance indicate changes here. ([canada.ca](https://www.canada.ca/en/department-finance/news/2026/01/government-launches-consultation-on-draft-legislation-for-previously-announced-and-technical-tax-measures.html?utm_source=openai))
- **SR&ED claims**: Without sufficient technical justification and documentation, claims may be delayed or rejected. The new elective pre-claim approval process will require clear project definitions. ([canada.ca](https://www.canada.ca/en/revenue-agency/corporate/about-canada-revenue-agency-cra/departmental-plan/2026-27-cra-departmental-plan.html?utm_source=openai))
## Practical Compliance Steps Businesses Should Take
1. **Review GST/HST practices**: Be ready for audits. If using input tax credits, maintain matching sales records and verify registration and filing compliance.
2. **Document inter-company transactions carefully**: If deferring income or using affiliate structures, ensure transfer pricing policies are documented and defensible. Avoid surprises in filings.
3. **Prepare SR&ED claims proactively**: For any project, map out eligible activities, their technical uncertainty, and keep contemporaneous documentation. Consider the new pre-approval elective route.
4. **Model cash flows under new personal tax rate structure**: If owner-managed corporations or sole proprietorships affected by changes in personal tax rates, review compensation strategy to optimize net take-home amounts.
5. **Monitor legislative consultations**: Tax rules on fuel charge rebates, global minimum tax, and income inclusions are under consultation. Participating in these can help shape outcomes. ([canada.ca](https://www.canada.ca/en/department-finance/news/2026/01/government-launches-consultation-on-draft-legislation-for-previously-announced-and-technical-tax-measures.html?utm_source=openai))
## Case Study: A Medium-size GST Refund Claim Audit
> **Scenario**: A manufacturing firm claims a large input tax credit in Q1 2026 for machinery purchased, but failed to track usage properly or ensure enough taxable sales in related periods.
>
> **Consequences**: CRA identifies inconsistency, requests supporting records; delays during audit, possibly penalties or reassessments. Refunds held up.
>
**Preventive Measures**:
- Ensure **matching of purchases to taxable sales**, usage logs, certificates if needed.
- Seek professional advice if undertaking **large capital purchases** that have mixed usage (exempt vs taxable).
## Conclusion
CRA is pushing for greater transparency, accuracy, and alignment with legislative policy. For businesses, the cost of non-compliance could be significant—not just monetary penalties, but lost opportunity costs. Updating internal compliance systems, documentation, and staying current with legislative developments is essential for risk mitigation.