CRA Updates SR&ED 2000-02R3: “Guidelines for Resolving Claimants’ SR&ED Concerns” [2016-05-30]
The Canadian Revenue Agency (CRA) released an updated guideline document detailing how the concerns of claimants for the Scientific Research & Experimental Development (SR&ED) program can be resolved.
The document details the responsibilities of all parties (i.e., SR&ED claimant, the CRA, and other stakeholders) as well as provides a step-by-step description on how to address concerns regarding filings and reviews. These guidelines were “established to ensure that SR&ED claimants’ concerns are addressed in a fair and timely manner.”
CRA Explanation of Changes
Reason for revision
The changes made to the guidelines address feedback received from stakeholders to improve the timeliness and consistency of the administrative review process for resolving claimants’ SR&ED concerns.
- Implementation of the request for an Administrative Review Form RC532 (PDF, 128 KB) that claimants’ must complete to request an administrative review.
- Implementation of a National SR&ED Administrative Review Intake Centre that will receive and catalogue all requests for administrative reviews, and forward each request to the appropriate tax services office.
- Wording in the guidelines has been revised for clarity.
The appendix provides a more detailed explanation of the changes:
- Form RC532 Request for Administrative Review – The form has been introduced as a means of ensuring that claimants and their representatives are providing the correct information to the CRA, in order to properly evaluate and act on the request
- National SR&ED Administrative Review Intake Centre – The intake centre is set up to help monitor the SR&ED Administrative Reviews. The intake centre will have no responsibility for completing the requests, but rather will distribute the requests and track progress and outcomes.
- Step 3 – The request for an Administrative Review cannot be initiated prior to the claimant receiving the Proposal Package. The premise is that, only once the claimant has the results of the SR&ED review are they able to fully understand CRA‘s position. It is at this point the claimant can best provide the CRA with a full explanation of their issue or complaint.
Thoughts on the Updated Guidelines for Resolving Claimants’ SR&ED Concerns
Now that Step 3 indicates that an Administrative review cannot be initiated prior to the claimant receiving the Proposal Package, it would be interesting to know how many were upset with the treatment by the CRA prior to the proposal package being received.
While we applaud the CRA for these changes, we can only hope that the establishment of a new “intake centre” will identify trends and propose improvements in the overall program administration, rather than simply treating the symptoms by introducing a new form.