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Application Policy: Third-Party SR&ED Payments (1996)

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At SREDucation, we’re taking the time to document all of the changes that have occurred to the SR&ED program over the years. In our “From the Archives” series, you’ll be able to see how the program has evolved since its inception in 1986. For a timeline of these events, check out the SR&ED Tax Credit page on Facebook. Stay current with the program by understanding the historical context. 

On July 12, 1996, the Federal government issued a notice concerning payments to third parties for SR&ED. The notice was intended to address questions such as how basic research qualifies, how to separate SR&ED in multidisciplinary research, and the documentation required for taxation purposes.

Third-Party Payments for SR&ED

As defined for taxation purposes, third-party payments qualify in these categories:

  • Associations;
  • Universities, colleges, and research institutes;
  • Corporations resident in Canada; and
  • An “approved organization” that makes payments to the above entities.

“The SR&ED must be related to a business of the taxpayer, and the taxpayer must be entitled to exploit the results of that SR&ED,” the notice stated. “Third-party payments should not be payments that can be used for purposes other than SR&ED.”

Documentation is also required to show who the payments were for, how much they were, and proving that they are related to SR&ED and the business of the claimant.

SR&ED Clarifications

The government also provided some clarifications on other terms:

  • Related to a business: “Some interconnection or link between the SR&ED work and the general area of a taxpayer’s business.”
  • Entitlement to exploit: “The taxpayer must have gained the right to use the results of the SR&ED in his business as a direct result of the payment.”
  • Basic research: “Related to a business if the outcome could have a direct and beneficial application to a taxpayer’s business. In other words, there must be the potential to gain knowledge from the SR&ED.”
  • Boundaries of SR&ED: “Any payment made by the taxpayer must be for the purposes of SR&ED.”

This article is based upon a Government of Canada notice issued at the time: Application Policy: Payments to Third Parties for SR&ED.


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