A landscaping company carries out different types of construction under some landscaping contracts such as excavation and rock fill, the installation of unistone or concrete sidewalks and the construction of small terraces or flower boxes. The invoice does not provide a breakdown of the price between the different types of work. Does its income come primarily from construction activity for the purpose of the T5018 slip filing requirement? CRA responded:
[T]he term "construction" in its ordinary meaning and …[Reg.] 238(1) … are broad enough to include most of the projects that could be qualified as landscaping. For example, some projects could be considered as the installation or improvement of a structure on the surface or sub-surface, the surface being the land or property.
A construction activity could include a task required to complete that construction activity or achieve the result of that construction activity, even though that task might not be a construction activity in itself if it were the only task performed in the framework of a landscaping project. As a result, it may not be appropriate to analyze revenues and separate them according to the tasks performed.