12 November 2013 Internal T.I. 2013-0497611I7 F - Feuillet T1204 -- summary under Subsection 237(2)

Should reimbursements for travel expenses of external consultants to a federal agency be included on the T1204 form? The Directorate responded:

[I]t is imperative to validate that the amount was paid or reimbursed under a services contract … . [I]f the relationship between the federal agency and the recipient of a payment is not contractual in nature, the form does not have to be filed.

…The term service generally refers to manual or intellectual work that has a certain value in the eyes of a customer. In our view, if to provide the service, the supplier must travel, the latter would be part of the service and would be included on the T1204 form.

...[A]ssuming that a contractual relationship exists between the consultants and the federal agency payer … reimbursements for travel expenses should be disclosed on the T1204 form.

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