Joint venture participants include their pro rata shares of JV payroll for provincial income allocation purposes

The general inter-provincial income allocation formula in Reg. 402(3) gives equal weighting to the relative payroll and gross revenues attributable to permanent establishments in the respective provinces.  CRA considers that where there is a joint venture carried on by the participants through an operator, for purposes of this formula each JV participant will include the share of the JV payroll incurred by the operator for which it has "legal responsibility."

Neal Armstrong.  Summary of 19 February 2014 Memo 2013-0508121I7 under Reg. 402(3).