The PCC Journal

The CRA Is Auditing Owner-Operators Again. Here's What Actually Protects You.

By Harsimran Grewal

The CRA lifted its T4A penalty moratorium for trucking and Budget 2025 funded a standing enforcement program aimed at Driver Inc. But legitimate owner-operators are getting swept into the reviews too. Here's the five-factor test and what to document.

Article

A B.C. trucker sold his truck last October after forty years on the road, most of them hauling for one carrier under a Unifor agreement. He'd incorporated in 2002, filed his corporate returns every year, remitted GST, and used the same accountant the whole way through. In June, a letter from the Canada Revenue Agency asked him to prove his corporation wasn't operating as a personal services business. He wasn't hiding anything. He was retired.

His story, reported by Truck News in July , isn't an outlier. It's what the CRA's new compliance push in trucking looks like on the ground, and it touches a lot of Chamber members directly, or someone in their orbit: a brother-in-law leasing a truck, a cousin running three rigs under one carrier contract, a driver who incorporated a decade ago because everyone told him it was the smart move.

What actually changed

For fourteen years, the CRA had a standing moratorium on penalizing trucking businesses that skipped box 048 of the T4A slip, the box that reports fees paid to another corporation for services. That moratorium ended on December 4, 2025 . If your business pays more than $500 in a calendar year to a Canadian-controlled private corporation in the trucking industry, you now have to report it, and failing to do so can cost you a penalty.

The rule applies to any business where trucking makes up more than half its income : carriers, freight brokers, owner-operators who subcontract drivers, all of it. Budget 2025 backed this with real money : $77.0 million over four years starting in 2026-27, with $19.2 million a year after that, earmarked specifically for CRA enforcement in trucking. This isn't a one-time sweep. It's a standing program.

The real target is the five-factor test

T4A reporting is the paperwork layer. The bigger question underneath it is whether your corporation counts as what the CRA calls a personal services business, or PSB, which is essentially an incorporated employee. The CRA's own fact sheet lays out the conditions:

You, or someone related to you, is a specified shareholder of the corporation.

The corporation provides services to another business: a carrier, a broker, a shipper.

You'd reasonably be considered that business's employee if your corporation didn't exist.

The corporation employs five or fewer full-time staff all year.

The payments it receives don't come from an associated corporation.

Get classified as a PSB and the tax bill changes shape fast. No small business deduction. No general corporate tax rate reduction. An extra 5% tax stacked on top of the full federal and provincial rates. And most of the expenses that make owning a truck worthwhile stop being deductible.

Where it gets messy

The test reads clean on paper. In practice, auditors are leaning hard on one factor: does this driver haul for a single carrier? Scott Taylor of Transport Financial Services told Truck News his firm is handling six reviews built almost entirely around that one fact, with too little weight given to who owns the truck, who carries the operating risk, and who could walk away and hire someone else to drive it. One of his Ontario clients was reassessed for roughly $130,000 after the CRA disallowed fuel, repair, and other operating expenses outright.

Accountant Kevin van Delden put the tension bluntly in the same piece: a corporate return showing a truck worth several hundred thousand dollars, plus genuine fuel and repair expenses, doesn't look like a shell built to dodge payroll tax. Hauling for one carrier is common in this business for a plain reason: the carrier supplies the insurance, the operating authority, and the freight. That's not proof of misclassification. It's how the industry runs.

What to have ready

You can't control how an auditor weighs the single-carrier factor. You can control how well-documented the rest of your case is before a letter shows up.

Proof you own or lease the truck in your own name, not the carrier's.

Records showing you cover fuel, repairs, and insurance: the costs an employee would never carry.

Anything showing you could take on another carrier or hire a second driver, even if you haven't.

A T4A slip from every carrier that pays your corporation more than $500 a year, and one issued from your corporation to anyone you subcontract.

A clean paper trail: corporate filings, GST remittances, payroll account, all current.

None of this guarantees a smooth review. It gives your accountant something to work with instead of reconstructing years of history under deadline pressure. The CRA's fact sheet on this is available in ten languages, including Punjabi, worth passing along to a driver, a bookkeeper, or a father-in-law who'd rather read it that way.

The bottom line

Driver Inc., carriers pushing drivers into incorporation to dodge payroll obligations, is a real problem, and the funding behind this crackdown is a signal it's being taken seriously. But the net is wide, and it's catching owner-operators who did everything by the book. If you run a trucking corporation, or you're the one signing T4A slips for subcontractors, this is the year to get the file in order before the CRA asks for it.

This is general information, not tax or legal advice. Talk to an accountant who knows the trucking sector before you change how your business is structured.

Want to talk through what this means for your operation with other Chamber members dealing with the same letters? Our events page has the next chance to do that in person.

Sources

CRA strengthens compliance in trucking sector by lifting the moratorium on T4A penalties — Canada Revenue Agency, December 4, 2025

Trucking industry: Make sure you're meeting your reporting obligations — Canada Revenue Agency, February 5, 2026

Compliance requirements for the trucking industry — Canada Revenue Agency

Minister Champagne clamps down on Driver Inc. scheme in Budget 2025 — Department of Finance Canada, October 30, 2025

Fact sheet – Personal services business — Canada Revenue Agency

CRA confirms focused trucking PSB crackdown amid concerns over owner-operator reviews — Truck News, July 10, 2026