CRA permits professionals who are sharing payroll expenses to jointly open up a single payroll account without being considered to be a partnership

A group of dentists, who are not in partnership, wish to share the costs of staff such as receptionists and bookkeepers and also are shared employers of the staff, so that all of the staff remuneration paid by each dentist is exempted from GST/HST as a result of being paid qua employer. CRA indicated that it can accept such an arrangement as being valid notwithstanding that all of the source deductions are handled on the payroll account of only one of the dentists, who does the remittances, and source deduction and T4 reporting, as agent for the other dentists as well as on her own behalf – and also pays the staff remuneration as agent and is reimbursed on a pro rata basis by the other dentists.

CRA also indicated that even though this arrangement is not a partnership either in Quebec or the Rest of Canada (because “both common law and civil law’s approach to partnership require an element that relates to profit sharing”), the group of dentists viewed as a “non-commercial partnership, or a partnership of employment or occupation” could alternatively jointly “open a Business Number (BN) payroll account for payroll purposes and remit and report under that BN.”

Neal Armstrong. Summaries of 25 February 2016 CBA Roundtable, Q. 7 under ITA s. 96 and s. 153(1)(a), ETA s. 123(1) – service.