Political Financing Handbook for Candidates and Official Agents (EC 20155) – June 2017 – DRAFT guideline OGI 2017-01
11. Working with Other Entities
This chapter discusses how transactions are regulated when the candidate's campaign engages in shared activities or shares expenses with other candidates, a registered association or the registered party. It covers the following topics:
- Shared expenses
- Prohibition on transferring expenses
- Property or services provided by the party or registered association
- Typical shared activities (leader's tour; campaigning by senators, ministers or another candidate; use of the registered association's resources)
Campaigns might decide to share the expenses of certain events during the election period, such as a speaking tour from a senator or another candidate. These expenses must be authorized in advance by the official agents of each campaign.
Each campaign that participates in a shared event must pay a reasonable allocation of the expense and report its share as an election expense. One campaign may not pay the expenses of another because transfers between campaigns are not allowed.
Expenses cannot be transferred
It is important to differentiate between the candidate's electoral campaign expenses and the expenses of the candidate's registered party. The Canada Elections Act specifies separate expenses limits for the registered party and each of its candidates.
The Act prohibits the transfer of expenses without accompanying property or services. Each entity has to report the expenses that it incurred for property and services used to promote that entity in the campaign.
Property or services provided by the party or registered association
Candidates may receive property or services from their registered party or a registered association of the party, such as signs and riding service packages. These can be received as non-monetary transfers or can be paid by the candidate's campaign.
If the property or service is being paid by the candidate's campaign, a copy of the original supplier invoice as well as the invoice from the party or association must be included with the candidate's return. The documentation should confirm the amount reported in the candidate's return.
For details on property or services already in place, including used signs and existing websites, see the Use of existing resources section in Chapter 8, Election Expenses.
- The candidate's registered party purchases signs from Signs Inc. for $1,500 and resells them to the candidate's campaign for $1,500. The party has to provide a copy of the original invoice from Signs Inc. for $1,500, as well as an invoice from the party for $1,500.
- The registered party creates a web page on its site for each candidate. The commercial value of creating the web pages is $150 per candidate. Each candidate has to report a non-monetary transfer and an expense of $150.
Typical shared activities
The following are examples of typical activities where various entities work together and might share expenses.
The party leader's tour expenses are election expenses of the party and may not be election expenses of the candidates. In addition to the expenses of transportation, the party has to include the expenses of all other related items, such as meals, refreshments, salaries of party staff assigned to the tour, and communications equipment rented for the media.
If the candidate's campaign incurs expenses to attend the leader's tour event, such as transporting campaign staff to the event, these are expenses of the candidate.
Campaigning by senators, ministers or another candidate
If a senator, a minister or another candidate campaigns on behalf of the candidate, the expenses related to that person's involvement in the campaign are election expenses and have to be authorized in advance by the official agent, the candidate or a person authorized in writing by the official agent.
Any expense incurred in relation to the campaign has to be reimbursed using campaign funds or accepted as a non-monetary contribution if paid by an eligible contributor, or as a non-monetary transfer if paid by the party or a registered association of the party.
In the event that a senator, a minister, or another candidate has travelled to a particular destination for purposes unrelated to the election and campaigns on behalf of the candidate while there, any incremental costs incurred to assist with the campaign are election expenses.
Use of the registered association's office and assets
The candidate's campaign may use the registered association's office and assets during the election period. Their use is an election expense.
For the use of its office, the registered association must send an invoice to the candidate's campaign together with the association's original rental agreement.
If the registered association charges:
- less than its own rental cost for the period, the difference is a non-monetary transfer from the association
- more than its own rental cost for the period, the difference is a monetary transfer from the candidate
For the use of its assets (computers, printers, etc.), the association must send an invoice equivalent to the commercial value of renting similar assets for the same period.
If the registered association does not charge for the use of its assets, the commercial value of renting similar assets for the same period is a non-monetary transfer from the association.
The registered association rents office space all year. During the election period, the candidate sublets the office and uses it as a campaign office. The registered association sends an invoice to the candidate's campaign for the rent calculated for the election period. The rent paid by the candidate is an election expense of the candidate. The registered association has to report the income in its financial statement at the end of the fiscal year.
Use of the registered association's online contribution system
The candidate's campaign might use the registered association's website to process online contributions, since associations often already have the necessary resources in place.
If a contribution is processed through the registered association's website to the association's bank account, the contribution is made to the registered association. The association issues the receipt and transfers the contribution amount to the candidate's campaign.
Keep in mind that the registered association's website is an election expense of the candidate if it stays online during the election period. See Use of existing resources in Chapter 8, Election Expenses, for more information.