Book Consultation

Gondaliya CPA

Section 67  ·  Outside TOSI  ·  Free Calculator

Paying Family Members From Your Corporation

A salary for real work is the one family income split the tax on split income rules never touched. Work out the defensible amount, the household saving, the payroll cost, and what happens if you pay more than the work is worth.

Salary is outside TOSI
Reasonableness tested
Employer costs included
Overpayment priced

Step 1 — The Work

Adult child

Spouse or partner
Adult child
Child under 18
Parent

All of them work. The rules are the same for each.


Real hours you could evidence, not notional ones


What you would pay a stranger to do exactly this work

Step 2 — The Money

Annual, before deductions


Anything they already earn elsewhere


The saving is the gap between your rate and theirs


Employer Health Tax only starts above $1,000,000


Percentage of insurable earnings. Enter 0 if not covered.

Household Position


net saving a year

Defensible Salary

Their Tax on It

Employer Cost

Net Household Saving

Is the Salary Defensible

TestBasisAmount

What the Household Actually Saves

ItemBasisAmount

Payroll Costs the Company Bears

CostBasisAmount

Documentation That Survives a Review

What to KeepWhy It Matters

Tax on the Same Money, Two Ways

Paid to your family member
Kept by you

Points That Decide This

    What to Do Next

    Disclaimer: Section 67 limits a deduction to an amount that is reasonable in the circumstances, and salary to a family member is deductible only to the extent it reflects what would be paid to an arm’s length person for the same work. Employment income is not split income, so the tax on split income rules in section 120.4 do not apply to it. Personal tax uses 2026 federal and Ontario brackets with the surtax and approximate basic personal amounts of $16,500 and $12,950. Canada Pension Plan contributions apply from age 18 at 5.95% between $3,500 and $74,600 and 4% between $74,600 and $85,000, matched by the employer. Employment insurance is generally not payable where the employee does not deal at arm’s length with the employer, though the CRA can rule otherwise, and this calculator assumes non-arm’s length treatment. The Ontario Employer Health Tax applies at 1.95% only on payroll above the $1,000,000 exemption. WSIB coverage and rates vary by industry. This page is general information, not tax advice.

    Salary Is the One Split TOSI Never Touched

    The tax on split income rules that arrived in 2018 closed almost every route to moving income to a lower-taxed family member. Dividends to a spouse, dividends to adult children, dividends to parents, all now taxed at the top rate unless a narrow exclusion applies.

    They did not touch salary. The rules apply to split income, which means dividends, certain interest and certain capital gains. Employment income is not split income and never was.

    That makes a salary for genuine work the last straightforward family income split available to an incorporated owner. It does not need an exclusion, it does not need a twenty-hour test, and it does not need the family member to hold shares. It needs the work to be real and the pay to match it.

    The Only Test That Matters

    Section 67 allows a deduction only to the extent it is reasonable. For a family salary that means one question: would you pay a stranger this much to do this work?

    FactorWhat the CRA Looks At
    HoursWhether the time was genuinely worked and can be evidenced
    RateWhat the same role pays at arm’s length in your area
    DutiesWhether the work is real and the business needed it done
    PaymentWhether money actually moved, rather than being accrued or journalled
    ConsistencyWhether the pay pattern looks like employment or like a year-end adjustment

    Overpaying Costs More Than It Saves

    Where the salary exceeds what the work is worth, the CRA denies the deduction on the excess. The family member is still taxed on it as employment income, so the excess is taxed twice, exactly like a shareholder benefit.

    On 15 Hours a Week at $28 an HourNet Household Saving
    Paying $22,000, close to the defensible $21,840$8,706
    Paying $60,000 for the same work$1,619

    Nearly tripling the salary destroyed 81% of the benefit. The extra pay attracts full personal tax, full employer contributions, and no corporate deduction. Getting the number right matters more than getting it large.

    Employment Insurance Usually Does Not Apply

    Employment between persons who do not deal at arm’s length is generally not insurable, which means no employee or employer premiums on a spouse or child. That saves roughly 3.9% of the salary between both sides.

    It also means no employment insurance entitlement, including maternity and parental benefits. For a spouse who may want those, it is worth asking the CRA for a ruling rather than assuming, because a ruling that the employment is insurable is sometimes the better outcome.

    A Child Under 18 Pays No CPP

    Canada Pension Plan contributions start at age 18. A child of sixteen working in the business genuinely costs the company nothing beyond the wage itself, and with the basic personal amount around $16,500 federally they will often pay almost no tax.

    The work still has to be real. A teenager doing filing, deliveries, social media or basic bookkeeping is entirely defensible. A teenager listed on payroll who has never been to the premises is not.

    What to Keep

    1. A written job description setting out the role and duties.
    2. Timesheets or a work log, kept as the work happens rather than reconstructed later.
    3. Evidence of the market rate, such as a job posting for a comparable role.
    4. Actual payments from the company account to their own account, on a regular cycle.
    5. Payroll registration, remittances and a T4, all done properly and on time.
    6. Some output, meaning emails, files, records or work product showing the job was done.

    The Saving Depends Entirely on the Gap

    The benefit is the difference between your marginal rate and theirs. An owner at the top rate paying a family member with no other income captures the whole spread. An owner in a low bracket, or a family member who already earns well, captures very little.

    SituationNet Saving on $22,000
    Owner at the top rate, family member with no other income$8,706
    Owner at the top rate, family member already earning $80,000$3,300
    Owner earning $60,000, family member with no other income$3,865

    What This Calculator Does Not Cover

    • Salary to the owner, which is a separate remuneration decision
    • Dividends to family members, which the split income rules do reach
    • RRSP room created by the salary, which is a genuine additional benefit
    • Childcare deduction interactions where a spouse’s income changes who claims
    • Provinces other than Ontario
    • Whether the corporation can afford it, which is a cash flow question rather than a tax one

    Set it up properly at the start and it is unremarkable. Reconstruct it after a review letter and it is very hard to defend. Our payroll service covers the registration, the remittances and the T4s.

    Frequently Asked Questions

    Common questions on family payroll.

    Can I pay my spouse a salary from my corporation?
    Yes, provided the work is real and the pay reflects it. Section 67 allows the deduction only to the extent it is reasonable, meaning what you would pay a stranger for the same work. Unlike dividends, a salary is not caught by the tax on split income rules, which makes it the most straightforward family income split still available.

    Does TOSI apply to a salary?
    No. The rules in section 120.4 apply to split income, which means dividends, certain interest and certain capital gains. Employment income is not split income. That is why a salary works where a dividend to the same person would be taxed at the top rate, and it needs no exclusion, no share ownership and no twenty-hour test.

    How much can I reasonably pay?
    Hours actually worked multiplied by what the role pays at arm’s length. Fifteen hours a week at $28 an hour supports about $21,840 a year. Paying meaningfully more than that invites the CRA to deny the excess, and because the family member is still taxed on it the excess ends up taxed twice.

    What happens if I overpay?
    The corporation loses the deduction on the excess while the family member still pays tax on it, so it is taxed twice exactly like a shareholder benefit. On our example, going from $22,000 to $60,000 for the same fifteen hours a week cut the net household saving from $8,706 to $1,619. Getting the number right matters far more than getting it large.

    Do I pay EI on a family member?
    Usually not. Employment between persons not dealing at arm’s length is generally not insurable, so neither side pays premiums, saving roughly 3.9% of the salary. The trade-off is no employment insurance entitlement, including maternity and parental benefits, so for a spouse who may want those it is worth asking the CRA for a ruling rather than assuming.

    Can I hire my teenage child?
    Yes, and it is efficient. Canada Pension Plan contributions do not start until age 18, so a sixteen year old costs the company nothing beyond the wage, and with the basic personal amount around $16,500 federally they often pay almost no tax. The work still has to be genuine, which for filing, deliveries, social media or basic bookkeeping is easy to support.

    What records do I need?
    A written job description, timesheets kept as the work happens, evidence of the market rate such as a comparable job posting, actual payments from the company account to theirs on a regular cycle, proper payroll registration and remittances, a T4, and some work product showing the job was done. Reconstructing all of that after a review letter is very hard.

    Is it worth it if my family member already has a job?
    Much less so. The saving is the gap between your marginal rate and theirs, so a family member already earning $80,000 captures only about a third of what someone with no other income would. Run your own numbers before setting up payroll, because the administration is the same either way and the benefit is not.

    Set It Up Properly Now, Not After the Review Letter

    Tell us the role, the hours and the person. We will set the defensible number, register the payroll, run the remittances and file the T4, so the arrangement stands up if anyone ever asks.

    Registered CPA Ontario — Firm ID 61330051
    1300+ Five-Star Reviews
    Fixed Fee, Including HST
    Weekend and Evening Access


    Scroll to Top