When the professional employees are called upon to perform duties early in the morning at the customer premises, they are asked to leave the place of business with an employer-owned automobile after their shift in order to proceed directly to their homes, thereby allowing them to proceed directly to the customer’s premises. CRA stated:
[T]here is no taxable benefit where an employee uses an Employer's automobile to drive from his or her home to the … customer. Similarly, there is no taxable benefit when the employee leaves the client's place of business and returns directly to the home, without passing through the Employer's offices.
With respect to the use by an employee of the Employer's automobile for travel between the Employer's place of business and the employee's home, it is generally the CRA's position that such use represents personal use of the automobile that gives rise to a taxable benefit under the standby charge.