The appellants, placement agencies, appealed tax assessments by the Minister of Revenue under the Employer Health Tax Act, arguing they were not the employers of temporary workers supplied to the federal government.
The court considered the tripartite relationship between the agency, the worker, and the client, and the definition of "employer" under the EHTA.
The court found that the appellants were the only entities with contractual obligations to pay the workers, and therefore were the employers for the purposes of the Act.
The appeals were dismissed.