Employees receive per-kilometre allowances for the actual kilometres driven by the employee in the employee’s automobile during the year, without distinction as to the number driven in the course of employment, and without the employer tracking this allocation. In rejecting a submission that this allowance should be construed as bifurcated into two allowances, one of which was reasonable as required by s. 6(1)(b)(x), CRA stated:
[I]n determining the reasonableness of a travel allowance, the phrase "solely on the number of kilometres for which the vehicle is used in connection with or in the course of the office or employment” (emphasis added) in subparagraph 6(1)(b)(x) refers to the use of the vehicle for business purposes only. Given the term "solely" used in the Act, an allowance is not deemed reasonable if it is attributable to use of the vehicle for other purposes. Furthermore, in our view, it is not possible to conclude that there are two separate allowances … .