13 March 2008 External T.I. 2008-0270151E5 F - Frais de location d'une automobile -- summary under Element E

A fleet management company, in addition to leasing automobiles to clients for the use of their employees and charging rent therefore, makes separate charges to those clients for additional services including the purchase of the vehicle from the dealer, the vehicle registration and other purchase related documentation, preparation of monthly reports, following-up on the return of vehicles at or before term, sale of the vehicle at its return, and annually calculating the taxable benefit. CRA stated:

[L]ease costs, including related costs, are not limited to costs related to the use of the automobile by an employee. Thus, we are of the view that all of the expenses listed above, with the exception of expenses charged by Opco to its clients for the purpose of making annual calculations of the taxable benefit to employees, constitute lease costs to be included in the description of E in subsection 6(2).

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