P11D travel costs paid directly by company

I doubt anyone will be able to give a definitive answer on this but wondered if anyone had any comments.

Having trawled through the HMRC legislation on the treatment of travel costs on a P11D I have been unable to ascertain whether payments made directly by a company (i.e not reimbursed expenses) in respect of employee's travel costs are reportable on form P11D.

I have always been under the impression that only re-imbursed expenses should be reported however I have recently got wind of the fact that all expenses should be included (even if paid directly by the company, including petty cash expenditure!).

Having read HMRC helpsheet 490: http://www.hmrc.gov.uk/helpsheets/490.pdf     this does indeed suggest that travel expenses paid directly by the company are included however then goes on to say items that are 'not taxable' do not need to be reported.

The most concerning matter is the end of the document (page 73) where it gives examples. The first says if an employer pays direct for an employee's travel costs (e.g settles employees hotel bill) then it is reportable on form P11D whereas if an employer pays directly for the travel costs of an employee attending a work related course this is not reportable. The only justification I can think of is that it may be less clear cut that a hotel bill is business related or the fact that a hotel bill may be in the name of the employee rather than the company.

Your thoughts please!