It is important that any intermediary have the capacity to do the job and that there be a “strong expectation” that the funds or resources transferred from the charity will be used appropriately.

In CRA’s Guidance “Using an Intermediary to Carry out a Charity’s Activities within Canada” it notes:

“4. What are the requirements when working with an intermediary?
A charity typically uses an intermediary when unable to carry out its own activities through its staff. The intermediary usually has resources that a charity needs, such as particular skills, resources, knowledge of a region, or specialized equipment.
Before deciding to work with an intermediary, and during the course of any such arrangement, a charity should investigate its status and activities to assure itself of the following conditions:
• The intermediary has the capacity (for example – personnel, experience, equipment) to carry out the charity’s activity.
• There is a strong expectation the intermediary will use the charity’s resources as directed by the charity.

When working through an intermediary, a charity must direct and control the use of its resources. [Footnote 12] A charity that does not direct and control its resources when working through an intermediary risks sanctions under the Income Tax Act, including the revocation of charitable status.
An intermediary can sometimes also be a beneficiary of a charity’s activity – for example, acquiring skills and expertise – while carrying out the activity. For more information on this type of situation, see Appendix A.
Any private benefit provided to an intermediary by a charity must be incidental and proportionate to any work being done. For example, a charity should ensure it pays a contractor only fair market value for any work done on its behalf.”

For more information on the CRA Guidance “Using an Intermediary to Carry out a Charity’s Activities within Canada” (Reference number CG-004) see: or