“The purpose of this application paper is to clarify when the Department will apply penalties under subsection 163(2) of the Income Tax Act (the Act) to overstated scientific research and experimental development (SR&ED) claims. This paper should be read in conjunction with TOM 13(163)0. This paper does not address the application of section 239 of the Act. However, some of the circumstances described with respect to the application of subsection 163(2) penalties may refer to actions which could be construed as tax evasion.”
IMPORTANT: These audio materials are presented only for non-commercial informational purposes. They have been reproduced, accurately and in whole, for non-commercial purposes from the Canada Revenue Agency (CRA) Scientific Research and Experimental Development (SR&ED) Program Policies. The original CRA text versions of the policies are available at http://www.cra-arc.gc.ca/
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