Bifalgorithm post · Fuscalite · CRA updates its SR&ED ITC policy

Expenditure Limit

Expenditure Limit (Fuscalite · CRA updates its SR&ED ITC policy) — "for taxation years beginning after December 15, 2024, the maximum expenditure limit has bee…

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  • For taxation years beginning after December 15, 2024, the maximum expenditure limit is $6M for CCPCs and ECPCs.
  • The new $6M limit applies to taxation years beginning after December 15, 2024.
  • CCPC rules use taxable capital or an elected revenue-based method to reduce the expenditure limit.
  • For CCPCs, the gradual reduction begins at $15M of taxable capital used in Canada in the previous taxation year.
  • The CCPC expenditure limit is reduced to nil after $75M of taxable capital used in Canada.
  • CCPCs may elect to calculate the reduction using revenue rather than taxable capital.
  • For ECPCs, the gradual reduction is calculated using average annual revenue over the last three fiscal years.
  • The rules concern the refundable investment tax credit, qualifying corporations, qualifying income limits, and ECPCs.
  • The summary is attributed to Neal Armstrong and the CRA webpage SR&ED Investment Tax Credit Policy dated 7 October 2026.
  • The cited provisions include sections 127(5), 127(9), 127(10.1), 127(10.2), 127(10.3), 127(10.5), 127.1(2), and 220(7).
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Expenditure Limit

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"for taxation years beginning after December 15, 2024, the maximum expenditure limit has been increased to $6M for CCPCs and ECPCs.\n\nfor CCPCs, the gradual reduction in the $6M limit now begins at $15M of taxable capital used in Canada for the previous taxation year and is reduced to nil after $75M;\n\nfor ECPCs, the average annual revenue over the last three fiscal years is used to calculate the gradual reduction of the $6M expenditure limit; and\n\nCCPCs may also elect to compute their reduction using this revenue-based method rather than their taxable capital.\n\nNeal Armstrong. Summaries of CRA Webpage, SR&ED Investment Tax Credit Policy 7 October 2026 under s. 127(5), s. 127(10.1), s. 127(10.2), s. 127(10.3), s. 127(10.5), s. 127.1(2) – refundable investment tax credit, qualifying corporation, qualifying income limit, s. 127(9) – ECPC, and s. 220(7).\n\n12 October 2026 - 11:29pm"

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