Les Investissements Nolinor Inc. v. ARQ, 2023 QCCQ 3835 -- summary under Paragraph 67.1(2)(d)

The taxpayer, which carried on a business of providing charter flights to generally remote locations, e.g., in Nunavut or Gabon, paid its pilots, crew and mechanics allowances of $3 to $5 per hour of flight to cover costs of meals and cleaning their uniforms. The ARQ denied 50% of the deductions claimed by the taxpayer for such allowances pursuant to TA s. 421.1 (similar to ITA s. 67.1(1).) Richard JCQ found that such amounts were deductible in full by virtue of the exception in TA s. 421.2(d) (similar to ITA s. 67(2)(d)) given inter alia that the allowances were in respect of remote work sites described in the Quebec equivalent of s. 6(6)(a)(ii).