Principal Issues:
(a) Is an allowance for the use of a motor vehicle in connection with the duties of an office or employment, based on a per-kilometer amount, a taxable benefit when it is adjusted to a minimum amount per round trip?
(b) Is an allowance for the use of a motor vehicle in connection with the duties of an office or employment, based on a per-kilometer amount, a taxable benefit when in the previous month an employee may have received a fixed amount plus a per-kilometer amount allowance?
(c) Is an allowance based on a per-kilometer amount for the use of a motor vehicle in connection with the duties of an office or employment, for travel outside the employment district, a taxable benefit when a fixed amount allowance is received per month for travel inside the employment district?
Position:
(a) Not if the amount is a reimbursement of actual expenses incurred.
(b) Not if the requirements of paragraph 6(1)(b) of the Act are otherwise met.
(c) The per-kilometer amount for travel outside of employment district is not taxable if the requirements of paragraph 6(1)(b) of the Act are otherwise met. The fixed rate amount for travel within the employment district is a taxable benefit by virtue of paragraph 6(1)(b)(x) of the Act.
Reasons:
(a) Paragraph 51, IT-522R.
(b) The amounts are separate allowances; the tax implications would be determined independently.
(c) The amounts are separate allowances; the tax implications would be determined independently.