19 September 1990 TI 902240

Where, in order to avoid GST on services provided by a management services corporation for a professional practice, the employees work directly for the professional practice and provide services to the management company without pay, their salary expenses will not be allowed as a deduction either to the professional practice or the management services company, nor will the 15% mark-up on services provided by the management services corporation be considered to be reasonable.

Where, in order to avoid GST on services provided by a management services corporation for a professional practice, the employees work directly for the professional practice and provide services to the management company without pay, their salary expenses will not be allowed as a deduction either to the professional practice or the management services company, nor will the 15% mark-up on services provided by the management services corporation be considered to be reasonable.