a corporation which acted predominantly as a staffing agency did not have a permanent establishment at the client premises where it placed staff. CRA stated:
It is our view that a placement agency can be distinguished from other service companies because the place where a personnel agency carries on its business may not include the place where its employees are assigned to perform employment duties. Case law...including Betteridge...Fonta...and Dunbar...supports the notion that business may not be carried on in a place simply by virtue that personnel have been placed there. However, if a placement agency provides specialized labour, it could be viewed that the corporation has entered the realm of being a contractor or subcontractor providing specialized services through an identifiable employee or employees.
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