Before concluding that it appeared likely that there was a taxable benefit from partial reimbursements to employees of fees for the use of recreational facilities for the purpose of engaging in physical activities, CRA stated:
Generally, we do not consider the payment or reimbursement of club dues or membership fees to be principally for the benefit of the employer where the employee's participation in physical activities provides only an indirect benefit to the employer. This is the case when the employee's health improves as a result of the physical activities resulting in an improvement in the employee's job performance (for example, the employee is sick less often). In such a case, the CRA considers that the employee primarily benefits from the payment or reimbursement and receives a taxable benefit for the purposes of paragraph 6(1)(a).
However, it is possible that the nature of the duties of a particular employment and/or the particular terms of an employment contract may require an employee to meet and maintain a certain level of physical fitness.