The taxpayer, which had queried whether it was required to file T5018 slips for payments made to subcontractors, was engaged in the installation of cabling, both public and residential lines – and also was involved in the construction of overhead and underground cables, the installation of equipment, the maintenance and renovation of networks, the interior and exterior pre-wiring of buildings and the installation and servicing of certain products. The Directorate stated:
The definition of construction activity is broad and we are of the view that it includes cable installation, construction of underground and aerial cables, maintenance, modification and upgrading of the cable network, installation of indoor and outdoor pre-wiring. ....
Determining whether income from construction activities represents more than 50% of the corporation's total income is a question of fact that requires an examination of all the facts and activities actually performed.