The split income rules do not apply to salaries
The split income rules, including in their proposed form, do not apply to salaries. Under the Gabco test, a salary is unreasonable if “no reasonable businessman would have contracted to pay such an amount having only [his] business considerations … in mind." This implies that:
[I]t may be justifiable and reasonable to pay a non-arm's-length person an amount in excess of an amount that would be paid to an arm's-length person if the non-arm's-length person exhibits, for example, a degree of loyalty and commitment that an arm's-length person could not….
Neal Armstrong. Summary of Alex Klyguine, "Income Splitting After the New Private Corporation Proposals: Salaries Paid to Family Members," Canadian Tax Focus (Canadian Tax Foundation), Vol. 8, No. 1, February 2018, p.2 under s. 67.