3 December 2018 CPA Canada Roundtable, 2018-0773811C6 - Tax on Split Income (TOSI) -- summary under Subparagraph (a)(i)

Gross income from services v. goods

Where goods are provided in combination with a service and the goods are not incidental (e.g., auto repairs and home renovations) the revenue from the goods will be considered. Conversely, services can be incidental to the sale of goods, e.g., the delivery and installation of goods sold. CRA recognizes that billing practices and accounting systems may not specifically identify revenue from non-services, so that there is flexibility when reviewing such situations.

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