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  • Question

    1) Is the argument given in the scenario background valid? 2) When is it appropriate to consider a tradeshow's primary purpose the dissemination of technical information if their is also effort to promote company image, etc.?


    Answer

    This response is based on the information provided.  We suggest you discuss with your contracting and finance team, program manager and/or legal department as appropriate. 
     
    The contractor's assertion that " there is no such thing as an allowable or unallowable tradeshow/airshow" is not incorrect.  What is allowable or unallowable are the costs of participating in a given airshow.  We do not believe that FAR 31.205-43 really pertains to tradeshows/airshows.  FAR 31.205-38 applies to the extent that it refers back to FAR 31.205-1. But tradeshows and direct selling are different.  The nature of tradeshows is broad and not targeted to a specific potential customer.  While direct selling may come from contacts made at a tradeshow, tradeshows on their face do not constitute direct selling.  FAR 31.205-1 does allow costs of tradeshows, subject to specific limitations identified in FAR 31.205-1(d)(2), if the contractor can make a case that its participation in the tradeshow is driven toward the promotion of exporting its products/services from the United States. 
    The second question you pose is not a FAR/DFARS question.  This is a judgment call.  Although subjective, you should apply certain objective considerations.  These considerations might be the overall nature of the event.  Is the targeted audience primarily foreign nations/companies?  IS the nature of the event heavily social or heavily technical?  What personnel is the company sending; more technical or more business development/sales? 
     

     

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