Does an employer providing free meals during overtime shifts count as a taxable benefit?

Often not, in limited and genuinely occasional circumstances — CRA has a recognized administrative accommodation that treats free meals provided during overtime work as non-taxable, but this treatment depends heavily on the meals being tied to occasional overtime rather than a regular, ongoing arrangement.

The frequency and pattern here really matter. A meal provided now and then, specifically because you were asked to work overtime on a particular occasion, fits comfortably within this accommodation. But if free meals during "overtime" shifts become a regular, ongoing feature of your work schedule — effectively a standing meal benefit rather than a response to occasional extra hours — that pattern looks less like the narrow accommodation CRA has in mind and more like an ordinary taxable benefit that happens to be provided around meal times.

Because this really is a frequency-and-circumstances question rather than a flat rule about "overtime meals" as a category, an employer providing meals during overtime regularly, or as a standard shift feature rather than an occasional accommodation, should look closely at whether the arrangement still fits within the narrow, occasional treatment CRA allows, or whether it's drifted into something that should actually be treated as taxable income for employees receiving it.