Table of Contents

Administrative Policy

8 January 2016 Interpretation 150125

agreement to be available to supply services was a supply of property

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.

Locations of other summaries Wordcount
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