Employees of a construction company work, for between a day and a few weeks, at various worksites in the province that are not their employer's place of business, and receive a travel allowance, for their travel by car between their home and the worksite, two rates of per-kilometer allowance based on whether the kilometers travelled exceeded a threshold.
CRA stated:
[T]he allowance is not reasonable since it is not based solely on the number of kilometers travelled by employees in fulfilling the duties of their employment. Those employees could therefore deduct all expenses incurred to travel from their place of residence to the worksites to which they are assigned. In fact, for the portion of their travel exceeding XXXXXXXX, the allowance paid for the travel exceeding XXXXXXXXXX would be deemed not to be reasonable, whereas the portion of their travel that is less than XXXXXXXXXX would not entitle them to an allowance.