SR&ED Penalties under Subsection 163(2) – Recording

SR&ED Penalties, Subsection 163(2)SR&ED Penalties under Subsection 163(2). This policy references Subsection 163(2) of the Income Tax ActThe summary from the CRA website is as follows:

“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


SR&ED Penalties under Subsection 163(2) – Recording


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Elizabeth Lance

Elizabeth is known as the "SR&ED Maven" in the industry. With a love of documentation and the nuances of language, she is often engaged by multi-million dollar companies to help improve documentation and workflow processes. Her favourite sentence (which she hears regularly) is "Accepted as Filed". Find out more about her on LinkedIn.