Regulation 237

Should reimbursements for travel expenses of external consultants to a federal agency be included on the T1204 form? The Directorate responded:

[I]t is imperative to validate that the amount was paid or reimbursed under a services contract … . [I]f the relationship between the federal agency and the recipient of a payment is not contractual in nature, the form does not have to be filed.

…The term service generally refers to manual or intellectual work that has a certain value in the eyes of a customer. In our view, if to provide the service, the supplier must travel, the latter would be part of the service and would be included on the T1204 form.

...[A]ssuming that a contractual relationship exists between the consultants and the federal agency payer … reimbursements for travel expenses should be disclosed on the T1204 form.

In indicating that reimbursements by the federal government for travel expenses of advisory committee members were not to be reported on a T1204 slip, CRA noted that the T1204 slip covers contract payments for government services, whereas here, the advisory committee did not have a contractual relationship with the government.

The person making the “contractual payments” at issue was not a “federal body” as defined in Reg. 237(1), so that no form T1204 filing was required. However, Reg. 200(1) required the filing of a T4A.