8 January 2016 Interpretation 150125
A stipend paid by a hospital to a medical specialist for agreeing to stay close to the hospital so as to be available on an on-call basis was taxable consideration for the supply of property to the hospital rather than for a supply of an exempt medical service. CRA stated:
[T]he hospital acquired a right to call upon the physician to attend the hospital during a given time period…[which] has a distinct utility to the hospital and as such…the right is a discrete supply that is separate from any health care services that may be rendered by the physician to patients of the hospital.
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|Tax Topics - Excise Tax Act - Schedules - Schedule V - Part II - Section 5||agreement of physician to be on call was a taxable property supply||270|