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Employee or self-employed? How the CRA decides

The factors used to decide whether a worker is an employee or an independent contractor, and why it matters.

Business Sapience Inc. · Last reviewed · 4 min read

Key points

  • The label in a contract is a starting point, not the answer; the actual working relationship decides.
  • Key factors include control, tools, subcontracting, financial risk, investment and the chance of profit.
  • Getting it wrong can leave the payer owing CPP, EI and penalties.

The central question

Is the worker in business on their own account, or working for someone else's business? Courts and the CRA first look at what the parties intended, then test that intention against how the relationship actually works.

The factors

FactorPoints toward employeePoints toward contractor
ControlPayer sets hours, methods and supervises the workWorker decides how, when and where the work is done
Tools and equipmentProvided by the payerWorker supplies and pays for their own
Subcontracting and helpersMust do the work personallyCan hire helpers or send a substitute
Financial riskExpenses reimbursed; no risk of lossBears own expenses, may lose money on a job
Investment and managementNoneInvests in the business, markets services, has other clients
Opportunity for profitPaid a fixed wage for timeCan increase profit through pricing and efficiency

Different rules apply in Quebec, where the Civil Code governs.

Why it matters

  • A payer that treats an employee as a contractor can be assessed for CPP and EI that should have been deducted, plus penalties and interest.
  • Contractors are generally not eligible for EI regular benefits and must manage their own tax and GST/HST.
  • An incorporated contractor who would otherwise be an employee may be carrying on a personal services business.

Either party can ask the CRA for a ruling on a worker's status using Form CPT1.

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