Pure agent exclusion clarified: reimbursable third party charges excluded from CHA taxable value when strict conditions are met. Exclusion of reimbursable third party charges from the taxable value of CHA services is allowed only where specific conditions are satisfied: the charge is for activities additional to core CHA services; an authorising arrangement exists allowing the CHA to procure and pay for such services on the customer's behalf; the CHA does not benefit from those services; reimbursements are recovered without mark up (any mark up mandates inclusion of the entire charge); evidential nexus between the reimbursed amount and the third party service is produced; each activity is separately invoiced or separately itemised; and miscellaneous out of pocket expenses are includable.
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Provisions expressly mentioned in the judgment/order text.
Pure agent exclusion clarified: reimbursable third party charges excluded from CHA taxable value when strict conditions are met.
Exclusion of reimbursable third party charges from the taxable value of CHA services is allowed only where specific conditions are satisfied: the charge is for activities additional to core CHA services; an authorising arrangement exists allowing the CHA to procure and pay for such services on the customer's behalf; the CHA does not benefit from those services; reimbursements are recovered without mark up (any mark up mandates inclusion of the entire charge); evidential nexus between the reimbursed amount and the third party service is produced; each activity is separately invoiced or separately itemised; and miscellaneous out of pocket expenses are includable.
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