Principal Issues: Whether meal allowances for ambulance drivers for trips to medical centres outside of the region where the drivers are based is a taxable benefit.
Position: The meal allowance would likely be excluded from income on the basis of the exception provided in subparagraph 6(1)(b)(vii) of the Act.
Reasons: It would appear reasonable to consider that an employee involved in patient transports, and that is regularly required to transport patients between municipalities, will nonetheless be considered to have an ordinary place of employment at the employer’s establishment where the employee is based. Therefore, the allowances provided to employees of the taxpayer for emergency transports outside of the municipality of the employer’s establishment where the employee is based would appear to qualify as meal allowances for travel outside of the municipality and metropolitan area where the employer’s establishment, at which the employee ordinarily worked, was located for the purposes of the exception in subparagraph 6(1)(b)(vii) of the Act.
