CRA states that a meal allowance based solely on kilometerage is not reasonable

A transport company paid its employees a meal allowance based solely on the number of kilometers traveled in the course of their employment, which took them on travel outside the municipal area where they normally reported to work. However, their travel never required them to spend the night away from home.

With this as context, CRA stated that “a meal allowance based solely on distance, time or any other criterion cannot, in itself, be considered a reasonable allowance” for purposes of s. 6(1)(b)(vii). CRA went on to provide a non-exhaustive list of factors it considered relevant in determining whether a meal allowance is reasonable, including:

• the average cost of ordinary meals in the area where the employee is travelling;

• the availability of food options along the employee's route;

• the availability of meals provided to the employee at no cost [e.g., is mom along the route?]; …

It would seem impracticable to expect employers to document this.

Neal Armstrong. Summary of 12 November 2025 External T.I. 2022-0923141E5 F under s. 6(1)(b)(vii).