Inter-company Management Fees

A detailed services agreement was not enough by itself to justify the deduction of management fees paid by Opco to Holdco. The court wanted evidence of the services rendered, the service hours provided, the hourly rate and the identity of the person who provided the services. See Bessette c Agence du revenu du Qu├ębec, 2014 QCCQ 4329, summarized in Tax for the Owner-Manager 14:4 (October 2014).

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