What happens after I file my SR&ED claim with the Canada Revenue Agency?
The Canada Revenue Agency (CRA)’s SR&ED Filing Requirements Policy states that in order for an SR&ED claim to be filed correctly, claimants must include the following:
- prescribed forms (Form T661 and Schedule T2SCH31 or Form T2038(IND), as applicable) containing the prescribed information in respect of an expenditure and the ITC [Income Tax Credit] earned on an expenditure by the SR&ED [Scientific Research and Experimental Development] reporting deadline; and,
- a T1, Income Tax and Benefit Return; a T2, Corporation Income Tax Return; a T3, Trust Income Tax and Information Return; or a Partnership Information Return (T5013 forms).1
However, once all of these and any other relevant forms have been completed and filed, what happens to an SR&ED claim?
This article identifies the five potential stages of the SR&ED claim review process, once the claim has been filed:
- Non-Technical Review
- General Review
- Specialist Review
- Financial Review
- Dispute Resolution Review
CRA Review Timeframes
The CRA review process begins once your forms have been sent to and logged at your local taxation centre, starting the clock on their mandated timeframes, which are detailed below:
- Refundable claims – 120 calendar days from receipt of a complete claim;
- Non-refundable claims – 365 calendar days from receipt of a complete claim;
- Claimant-requested adjustments to refundable claims – 240 calendar days from receipt of a complete claim; and
- Claimant-requested adjustments to non-refundable claims – 365 calendar days from receipt of a complete claim.2
The CRA’s SR&ED Filing Requirements Policy provides some additional insight on how quickly claims are processed depending on how they are received by the tax office:
Claims that are hand-delivered will be considered filed on that day. First-class mail or daily service will be considered filed on the date of the postmark. If the SR&ED reporting deadline happens to fall on a Saturday, Sunday or a public holiday recognized by the CRA, the filing deadline is extended to the next business day. Some recognized public holidays are specific to a province or territory. For a detailed listing of public holidays recognized by the CRA, please refer to the CRAWeb site.
For claims received through CRA‘s Corporation Internet Filing service, the filing date is the date that the confirmation number is issued.3
At Your Local CRA Taxation Centre
At the taxation centre, your claim forms are reviewed for completeness to ensure that all the fields have been filled in. Your claim is then scanned to see if your write-up sounds appropriately technical. The forms are then assessed based on the following categories, among others:
- financial size;
- change from prior years;
- any prior adjustments;
- date of the last review;
- presence of projects spanning more than 3 years; and,
- previous eligibility findings.
The reviewer generally does not have a technical background, but if your claim seems in line with past claims and the forms are complete, they will often recommend that it be accepted as filed. In this case, the result is a fast turnaround on your claim amount. If there is too much of a change in costs (i.e. amounts are either too high or too low) between years, or there are any other areas of concern, the claim is then passed to the Taxation Services Office.
At the CRA Taxation Services Office
We have created a list of all the taxation services offices in Canada. Taxation Services Offices (TSOs) do not offer a “walk-in counter service […] in any [location].”4
Research and Technology Officer – General Technical Review
The Research and Technology Officer (RTO) will have a science or technology background and will perform a general technical review, in which they search for possible non-eligible activities and expenses. The RTO is looking for a solid technical / technological tone. Additionally, the RTO looks for so-called “trigger words”—words that should not be used as they discredit the claim or the work performed.
However, if there are no obvious issues or comments about the claim in the CRA database, the RTO might recommend downscreening—accepting the document as is. However, if the RTO has any questions or concerns, they will make notes of potential non-compliance issues, and the file will then be transferred to a Research and Technology Advisor.
Research and Technology Advisor – Specialist Review
Research and Technology Advisors (RTAs) generally have more specific education and experience than RTOs, and they will have specialized expertise in the particular area of the claim. Their role is to verify whether the comments and concerns of the RTO warrant further investigation, which may include a visit to the claimant. In theory, RTAs are only supposed to visit if there appears to be a significant potential non-compliance issue; however, this varies by individual RTA and region. If an RTA does decide to visit with the claimant to discuss the claim, they will be looking for documented proof to substantiate the claim.
Financial Reviewers have a background in accounting or financial management and will analyze the financial information in the claim, including items such as eligible costs.
Be aware that, after a review, there may be additional questions. These should be put in writing so that there is proof of their being asked, but they often go undocumented. Due to this, it is important to always confirm the questions with your RTA prior to submitting additional documentation, to ensure efficient processing of the information.
If the SR&ED Claim’s Eligibility is Disputed
Research and Technology Manager – Dispute Resolution
Research and Technology Managers (RTMs) supervise and manage RTAs, and are required to sign off on the technical and financial reports produced by the RTA if an adjustment is made. In the event of a dispute arising between the assessment of the claim by the RTA and the claimant, or if there are concerns or questions regarding the RTA or the review, the RTM is the individual you should contact.
All claims go through the same initial process with officers at the CRA. More complex or disputed claims will go through additional stages for the CRA to reach a final verdict.
Occasionally, the CRA will request to review an SR&ED claim further. We have written more about surviving SR&ED reviews and what to do if you want to dispute CRA’s assessment of your claim in other articles.
Do you still have questions about where your SR&ED claim is going and how long it might take to process?
Our Comprehensive Guide to SR&ED includes more information about reviews and writing tips to avoid them – sign up today!
Have you ever had a claim review? Do you have any insight into the SR&ED claim review process?
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- Government of Canada. (December 18, 2014.) SR&ED Filing Requirements Policy. Question 1 What is the difference between an SR&ED claim that meets the SR&ED filing requirements and the requirements for processing an SR&ED claim? Processing an SR&ED claim. (Accessed: October 3, 2017.) Retrieved from: https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/filing-requirements-policy.html#s8_1. ↩
- Government of Canada. (April 21, 2017.) SR&ED Program Service Standards. (Accessed: August 24, 2017.) Retrieved from: https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/program-service-standards.html. ↩
- Government of Canada. (December 18, 2014.) SR&ED Filing Requirements Policy. (7.4) Date Received. (Accessed: October 3, 2017.) Retrieved from: https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/filing-requirements-policy.html#s7_4. ↩
- Government of Canada. (May 30, 2016.) Tax services offices and tax centres. (Accessed: August 24, 2017.) Retrieved from: https://www.canada.ca/en/revenue-agency/corporate/contact-information/tax-services-offices-tax-centres.html. ↩