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SR&ED Allowable vs. Qualified Expenditures: What are they?

SR&ED Allowable vs. Qualified Expenditures: What are they? (Photo Credit: Mikhail Nilov via Pexels.com)

The Canada Revenue Agency’s (CRA) Scientific Research and Experimental Development (SR&ED) Investment Tax Credit (ITC) program is complex, and understanding what costs you can claim for SR&ED can be confusing. In addition, the language used by the CRA is unique, and if you are not immersed in it on a day-to-day basis it is easy to be misled by the terminology. In this article, we discuss two seemingly simple terms in the SR&ED program, allowable and qualified SR&ED expenditures. Allowable SR&ED expenditures and qualified SR&ED expenditures are not the same thing. Allowable SR&ED expenditures include the directly attributable expenditures incurred while completing the SR&ED work for the tax year, and qualified expenditures are all the amounts that qualify for calculating the SR&ED ITCs in a tax year. In this article, we break these terms down and discuss the difference between them.

SR&ED Allowable vs. Qualified Expenditures: What are they?

Both terms, Qualified SR&ED expenditures and Allowable SR&ED expenditures are used throughout Form T661, Scientific Research and Experimental Development (SR&ED) Expenditures Claim and it is important to know the difference between them.

The term Qualified SR&ED expenditures is defined in the SR&ED Glossary as:

 […] all the amounts that qualify for calculating the investment tax credit in a tax year.1

The term Allowable SR&ED expenditures is not defined in the SR&ED glossary, however, the CRA has included the definition on their newly organized SR&ED pages as

The expenditures you incurred conducting SR&ED work.”2

Essentially, a company’s qualified SR&ED expenditures include their total allowable SR&ED expenditures adjusted according to amounts the company paid or received. Before calculating the qualified expenditures, the company must first confirm that SR&ED work did occur and group said work into SR&ED projects, then they must calculate the total allowable SR&ED expenditures. These amounts will be entered in “Section B – Calculation of allowable SR&ED expenditures” on Form T661. See Business Project vs. SR&ED Project: Not the Same for guidance on how to separate SR&ED work from non-SR&ED work.

Calculating SR&ED Allowable Expenditures

When claiming SR&ED tax incentives, only the expenditures directly attributable to the prosecution of SR&ED may be included. This means the claimant must first calculate how much they spent in relation to their SR&ED work only during the tax year. The SR&ED Salary or Wages Policy discusses the appropriate splitting of costs, stating that:

the legislation clearly indicates that only an expenditure that can reasonably be considered to relate to the prosecution of SR&ED can be allowed as an expenditure for SR&ED purposes. There must be a reasonable link between the amount of salary or wages and the SR&ED work being performed for an amount to be an allowable SR&ED expenditure.3

The following expenditures can be included once the costs have been properly allocated and all the non-SR&ED expenditures are removed:

  • Salary or wages
  • Materials (consumed or transformed)
  • Contracts for SR&ED
  • Overhead and other expenditures (traditional method only)
  • Third-party payments

Salary or Wages

The salary or wages of employees who are directly engaged in SR&ED, doing hands-on work, should be included in the calculation of the total allowable SR&ED expenditures. The salary or wages must be based on the time employees spent on SR&ED activities and the tasks they performed.4 Allowable expenditures for salary or wages are entered on Lines 300-309 of Form T661:

T661 Scientific Research and Experimental Development (SR&ED) Expenditures Claim

The rules differ if the traditional method is used. See “Proxy vs Traditional SR&ED Claim: Which Method to Choose?” for more information.

There are also unique rules for claiming the salary or wages of employees who conducted SR&ED work outside Canada. See our articles “SR&ED Outside Canada” Series Part Two: Overhead and Other Expenditures and “SR&ED Outside Canada” Series Part Three: Salaries and Wages Outside Canada.

Materials (consumed or transformed)

The Materials for SR&ED should be included in the allowable SR&ED expenditures. Materials for SR&ED include all the “raw materials, substances, or other items that compose the body of a thing at any time during the SR&ED work carried out in the tax year.”5 The cost of materials consumed is entered on Lines 320, and the cost of materials transformed is entered on Line 325 of Form T661:

T661 Scientific Research and Experimental Development (SR&ED) Expenditures Claim

See CRA Policy Review – Materials for SR&ED for details on the difference between material transformed and materials consumed, and how the material costs may be included in the calculation of SR&ED ITCs.

Contracts for SR&ED

The Contract expenditures for SR&ED should be included in the total allowable SR&ED expenditures. A company may claim the amount they paid or that was payable to contractors or sub-contractors who did SR&ED work in Canada on their behalf during the tax year, however, the contract expenditures between arm’s length contractors and non-arm’s length contractors must be separated as different rules apply to each.6 Our article Non-arm’s length vs. Arm’s length Contract Expenditures in SR&ED delves further into the complexities of the two types of contracts and how they impact the claimant’s SR&ED claim. The Arm’s length contract expenditures are entered on Lines 340, and the Arm’s length contract expenditures are entered on Line 345 of Form T661:

T661 Scientific Research and Experimental Development (SR&ED) Expenditures Claim

Contract expenses incurred by a subcontractor outside of Canada are not allowed to be included in the calculation of allowable expenses. See SR&ED Contracts Expenditures Outside of Canada for more information.

Overhead and other expenditures (traditional method only)

If the traditional method is used then the claimant should include the directly attributable overhead and other expenditures in their total allowable SR&ED expenditures. The CRA defines Overhead and Other Expenditures as:

certain expenditures of a current nature that are directly related to the prosecution of SR&ED in Canada and that are incremental, or to certain expenditures that are directly attributable to the provision of premises, facilities, or equipment for the prosecution of SR&ED in Canada.7

Read through the SR&ED Overhead and Other Expenditures Policy for details on what expenditures are considered to be directly related to the prosecution of SR&ED and how these expenditures affect the final SR&ED ITCs.

The SR&ED Overhead and Other Expenditures are entered on Lines 360 of Form T661:

T661 Scientific Research and Experimental Development (SR&ED) Expenditures Claim

Third-party payments

Any Third Party Payments the claimant made in their fiscal year for SR&ED should be included in their total allowable SR&ED expenditures. These payments can be direct financial contributions, funding for students or employees doing the SR&ED work, or payments in kind, however, they can only be claimed as an allowable expenditure if:

  • the work is done by an approved entity or a third-party entity accepted by the CRA,
  • the work relates to the claimant’s business, and
  • the claimant is entitled to exploit the results of the work8

See our article Third-Party Payments vs. Contracts (T661 Lines 340, 345, and 370) and the Third-Party Payments Policy for full details on third-party payments and SR&ED. The third-party payments will populate on Line 370 of Form T661 after Form T1263, Third-Party Payments for Scientific Research and Experimental Development is completed:

T661 Scientific Research and Experimental Development (SR&ED) Expenditures Claim

Calculating SR&ED Qualified Expenditures

As discussed above, qualified expenditures are the amounts that qualify for calculating the investment tax credit in a tax year and calculating the total qualified SR&ED expenditures includes adjusting the total allowable SR&ED expenditures according to amounts that were paid or received in the tax year.9 In this section we will discuss the additions and deductions that must be applied to calculate a claimant’s final qualified expenditures for SR&ED ITCs.

Additions

  • Prescribed proxy amount (if you used the proxy method)
  • Payment of unpaid amounts from previous years
  • Qualified expenditures that were transferred to you10

The Prescribed Proxy Amount (PPA)

The PPA is defined by the CRA as:

“a notional amount on which SR&ED ITC can be earned. It is calculated as a percentage of a salary base. The PPA is only applicable when the claimant elects to use the proxy method.”11

The PPA is used in lieu of actual SR&ED overhead and other expenditures when calculating qualified SR&ED expenditures to earn SR&ED ITC under the Proxy method.12 As of 2014, the PPA is calculated as 55% of the salary base, and this calculates at Line 820 of Form T661:

T661 Scientific Research and Experimental Development (SR&ED) Expenditures Claim

For more information on how to calculate the PPA and PPA Cap see our article “What is the Prescribed Proxy Amount (PPA) Cap?

Unpaid Amounts From Previous Years

Any expenditures for SR&ED which are of a current nature and that were unpaid within 180 days after the end of the company’s tax year are deemed not to have been incurred in that fiscal year, but rather to be incurred at the time that it is actually paid. The unpaid expenditures are still included in the pool of deductible SR&ED expenditures in the tax year that they are incurred.13 This means that any payment of prior years’ unpaid amounts, other than salary or wages (see note below), must be added to qualified SR&ED expenditures in the year that they were actually paid.

Payment of prior years’ unpaid amounts (other than salary or wages) is entered on Lines 500 of Form T661:

T661 Scientific Research and Experimental Development (SR&ED) Expenditures Claim

Note: Separate rules apply to unpaid salary or wages and other remuneration: Not only are they not included for ITC purposes, but they are also not included in the pool of deductible SR&ED expenditures. For more information on unpaid salary or wages, please refer to section 11.0 of the SR&ED Salary or Wages Policy.14

Qualified Expenditures Transferred to the Claimant

If the payer of the SR&ED is not dealing at arm’s length with the performer of the SR&ED, then the performer may transfer its qualified SR&ED expenditures to the payer up to a maximum of the contract amount.15

To make such a transfer, the payer and the performer must each complete their own copy of Form T661, and Form T1146, Agreement to Transfer Qualified Expenditures Incurred in Respect of SR&ED Contracts Between Persons Not Dealing at Arm’s Length.16 Qualified expenditures transferred to the claimant must be entered on Lines 508 of Form T661:

T661 Scientific Research and Experimental Development (SR&ED) Expenditures Claim

See our article Non-arm’s length vs. Arm’s length Contract Expenditures in SR&ED for more details about how to transfer expenditures between non-arms length companies.

Deductions

  • Provincial and territorial government assistance in respect of SR&ED
  • Other types of government or non-government assistance in respect of SR&ED
  • 20% of contract payments and third-party payments
  • Non-arm’s length transactions
    • Adjustments to your purchases (limited to costs) of goods and services from non-arms length suppliers
    • Qualified expenditures you transferred
    • Assistance allocated to you
    • Expenditures for your non-arm’s length SR&ED contracts17

Government and non-Government financial assistance for SR&ED

When calculating qualified SR&ED expenditures, any government and/or non-government assistance payments should be reflected in the SR&ED claim in the tax year in which the SR&ED began.18 Financial assistance that a claimant has received, is entitled to receive, or can reasonably be expected to be received for SR&ED that began in a tax year, will reduce the qualified expenditures in that year or a subsequent year:

Any excess financial assistance that is not applied to the project in the current tax year will be carried forward to reduce qualified expenditures of that project in a subsequent tax year.19

The reduction of financial assistance from qualified expenditures should be calculated on a project-by-project basis. This means that the financial assistance received in respect of one project will not reduce the expenditures of another project.20

The CRA states that for each project, the amount of financial assistance that reduces the qualified expenditures is the lesser of:

“1. the total of all amounts of assistance… in respect of the SR&ED that, at the claimant’s filing-due date for the tax year, the claimant has received, is entitled to receive, or can reasonably be expected to receive, less any amounts of assistance… applied in preceding tax years; or

2. the total project costs related to that project for the tax year.”21

Provincial and territorial government assistance in respect of SR&ED populates in Lines 429(a-d2) and 513(a-d2) of Form T661 for Quebec, Ontario, British Columbia, and Alberta. If the claimant reside in another province then any provincial/territorial government they received for SR&ED must be entered in Lines 429e and 513e of Form T661. Other types of government or non-government assistance in respect of SR&ED, such as IRAP and CEWS, must be entered in Lines 431 and 515 of Form T661:

T661 Scientific Research and Experimental Development (SR&ED) Expenditures Claim

Contract and Third-Party Payments

Contract payments for SR&ED are considered to be an allowable SR&ED expenditure, however, only 80% of the contract payment is allowable as a qualified SR&ED expenditure for ITC purposes.22

In addition, to avoid the duplication of the ITC, the party performing the contract (the performer), reduces the qualified SR&ED expenditures for ITC purposes by the contract payment. This means only the party which pays the contract (the payer) may claim the expenditures related to the contract payment.

The rules for arm’s length and non-arms length contractor payments have different rules and can be confusing. Read Non-arm’s length vs. Arm’s length Contract Expenditures in SR&ED for more details about how contract payments are dealt with in both cases, and see the “Non-arm’s length (NAL) Transactions” section below.

The rules for third-party payments follow the same 80% rule as contract payments in terms of allowable vs. qualified expenditures. The Third-Party Payments Policy states:

“Only 80% of the third-party payment is included in the qualified SR&ED expenditures and this amount qualifies for investment tax credit purposes.”23

A third-party payment is generally a payment made to an entity to be used for SR&ED carried on in Canada, that is related to the claimant’s business and the claimant must be entitled to exploit the results of the SR&ED.24 We discuss the intricacies of third-party payments in “SR&ED Third-Party Payments vs. Contracts (Lines 340, 345, and 370)“.

20% of all contract and third-party payments are calculated and removed from the qualified SR&ED expenditure pool at Line 529 of Form T661:

T661 Scientific Research and Experimental Development (SR&ED) Expenditures Claim

Ensure that 20% of all arm’s length contract payments and all third-party payments are removed in order to properly calculate your total qualified SR&ED expenditures.

Non-arm’s length (NAL) Transactions

The CRA has specified specific expenses that must be removed from NAL transactions to calculate the qualified SR&ED expenditures for the tax year including:

  1. Any qualified expenditures transferred from the claimant to their NAL counterpart (must be entered on Line 544 of Form T661)
  2. Any assistance allocated to the claimant (must be entered on Line 538 of Form T661)
  3. Any contract expenditures for SR&ED performed on behalf of the claimant by a performer with whom the claimant is not dealing at arm’s length (Populates on Line 541 of Form T661)
  4. any adjustment resulting from purchases of goods and services from non-arms length suppliers (must be entered on Line 542 of Form T661)25

Non-arm’s length (NAL) transactions are removed from the qualified expenditure pool in Lines 538-544 of Form T661:

T661 Scientific Research and Experimental Development (SR&ED) Expenditures Claim

1) Qualified expenditures transferred from the claimant to their NAL counterpart:

The amount of qualified expenditures the claimant transferred to a NAL counterpart must be deducted from the SR&ED qualified expenditure pool of a claimant.

NAL parties within a contract agreement may choose to transfer qualified SR&ED expenditures up to a maximum of the contract amount. To make such a transfer, the payer and the performer must each complete their own copy of Form T661, and Form T1146, Agreement to Transfer Qualified Expenditures Incurred in Respect of SR&ED Contracts Between Persons Not Dealing at Arm’s Length.26

2) Financial assistance allocated to the claimant:

The Assistance and Contract Payments Policy states that any financial assistance amounts that were not applied to the recipient’s qualified SR&ED expenditures must be allocated among the members of a non-arms length group if:

  • each member of the group performs the SR&ED when the member is not dealing at arm’s length with the recipient of the assistance; and
  • the amount of the assistance is less than the total qualified SR&ED expenditures of the non-arms length members of the group on the SR&ED in respect of which the assistance was received.27

Any agreement to allocate assistance is only valid if:

The SR&ED Filing Requirements Policy was last updated in November 2020, we discussed the changes in our article “Updates to the SR&ED Filing Requirements Policy“. Be sure you are familiar with and up to date so you do not miss any important deadlines or forms.

3) Contract expenditures for SR&ED performed on behalf of the claimant by a NAL performer:

If a claimant (known as the payer) contracts a person (known as the performer) to carry on SR&ED on its behalf, and the payer and the performer are not dealing at arm’s length, the expenditures incurred by the payer for the NAL contract are not included in the total qualified SR&ED expenditures for ITC purposes. These expenditures must be deducted from the total allowable expenditures to calculate the total qualified expenditures.29

Read our article “Non-arm’s length vs. Arm’s length Contract Expenditures in SR&ED” for more details about contract payments are dealt with in a NAL scenario.

4) Adjustments resulting from the purchases of goods and services from NAL suppliers:

If goods or services (other than contracts for SR&ED) are purchased from a person (or partnership) that the claimant does not deal at arm’s length with, then the amount eligible for an ITC is only allowed to be claimed by the NAL person (or partnership) which provided the goods or services.30

Before 2014 the goods or services expenditures could include the lease or rental of equipment, the purchase of materials, and Shared-use equipment (SUE) costs, however, currently only service costs (E.g. maintenance, servicing equipment, clerical services) may be considered in a NAL scenario, and theses costs would be considered as SR&ED overhead and other expenditures.31 See the “Overhead and other expenditures (traditional method only)” section above for what costs fall under this category.

To calculate the amount resulting from the purchases of goods and services from NAL suppliers the following guidelines must be followed:

  • for a service provided to the claimant, either the expenditure the claimant incurred or the adjusted service cost is to be used as overhead or other expenditures, whichever amount is less.32

These costs are only claimable under the traditional method as overhead and other expenditures, and may only be claimed by the NAL party which provided the goods or services. Therefore, the cost must be deducted from the pool of qualified SR&ED expenditures of the NAL party which received the services.33

Conclusion

Allowable SR&ED expenditures and qualified SR&ED expenditures are not the same thing. Allowable SR&ED expenditures include the directly attributable expenditures incurred while completing the SR&ED work for the tax year including: salary or wages, materials (consumed or transformed), contract expenditures for SR&ED, overhead and other expenditures (traditional method only), and third-party payments. The qualified expenditures are all the amounts that qualify for calculating the SR&ED ITCs in a tax year. To calculate the total qualified SR&ED expenditures the claimant must add the prescribed proxy amount (if they are using the proxy method), any payment of unpaid amounts from previous years, and any qualified expenditures that were transferred to them from NAL contractors. Then all government and non-government assistance in respect of SR&ED, 20% of all contract and third-party payments, and any non-arm’s length transactions need to be deducted from the allowable SR&ED expenditure. The final total qualified expenditures for SR&ED goes on Line 570 of Form T661 and will be used to calculate the claimant’s final SR&ED ITCs. See our article “Maximum SR&ED Refund: Federal & Provincial ITCs (Ontario)” for an example of how the final SR&ED ITCs are calculated.

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Show 33 footnotes

  1. Government of Canada. (August 13, 2021). SR&ED Glossary: Qualified SR&ED expenditures. Retrieved August 9, 2023, from: https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/glossary.html
  2. Government of Canada. (July 19, 2023). Scientific Research and Experimental Development (SR&ED) tax incentives: Calculate allowable expenditures. Retrieved August 9, 2023, from: https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/sred-claim/allowable-expenditures.html
  3. Government of Canada. (December 18, 2014). SR&ED Salary or Wages Policy. Retrieved August 9, 2023, from: https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/salary-wages-policy.html#s8_3
  4. Government of Canada. (July 19, 2023). Scientific Research and Experimental Development (SR&ED) tax incentives: Calculate allowable expenditures. Retrieved August 9, 2023, from: https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/sred-claim/allowable-expenditures.html
  5. Government of Canada. (July 19, 2023). Scientific Research and Experimental Development (SR&ED) tax incentives: Calculate allowable expenditures. Retrieved August 9, 2023, from: https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/sred-claim/allowable-expenditures.html
  6. Government of Canada. (July 19, 2023). Scientific Research and Experimental Development (SR&ED) tax incentives: Calculate allowable expenditures. Retrieved August 9, 2023, from: https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/sred-claim/allowable-expenditures.html
  7. Government of Canada. (August 13, 2021). SR&ED Glossary: Overhead and other expenditures. Retrieved August 9, 2023, from: https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/glossary.html
  8. Government of Canada. (July 19, 2023). Scientific Research and Experimental Development (SR&ED) tax incentives: Calculate allowable expenditures. Retrieved August 9, 2023, from: https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/sred-claim/allowable-expenditures.html
  9. Government of Canada. (August 13, 2021). SR&ED Glossary: Qualified SR&ED expenditures. Retrieved August 14, 2023, from: https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/glossary.html
  10. Government of Canada. (July 19, 2023). Scientific Research and Experimental Development (SR&ED) tax incentives: Calculate qualified expenditures. Retrieved August 14, 2023, from: https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/sred-claim/qualified-expenditures.html
  11. Government of Canada. (August 13, 2021). SR&ED Glossary: Prescribed proxy amount (PPA). Retrieved August 14, 2023, from: https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/glossary.html
  12. Ibid
  13. Government of Canada. (December 18, 2014). Total Qualified SR&ED Expenditures for Investment Tax Credit Purposes Policy. Retrieved August 14, 2023, from: https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/total-qualified-expenditures-investment-tax-credit-purposes-policy.html
  14.  Ibid
  15. Government of Canada. (December 18, 2014). Total Qualified SR&ED Expenditures for Investment Tax Credit Purposes Policy. Retrieved August 14, 2023, from: https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/total-qualified-expenditures-investment-tax-credit-purposes-policy.html
  16. Ibid
  17. Government of Canada. (July 19, 2023). Scientific Research and Experimental Development (SR&ED) tax incentives: Calculate qualified expenditures. Retrieved August 14, 2023, from: https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/sred-claim/qualified-expenditures.html
  18. Government of Canada. (December 14, 2014). Assistance and Contract Payments Policy. Retrieved August 14, 2023, from: https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/assistance-contract-payments-policy.html
  19. Ibid
  20. Ibid
  21. Ibid
  22. Government of Canada. (March 30, 2022). Contract Expenditures for SR&ED Performed on Behalf of a Claimant Policy. Retrieved August 14, 2023, from: https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/contract-expenditures-performed-on-behalf-a-claimant-policy.html
  23. Government of Canada. (March 30, 2022). Third-Party Payments Policy. Retrieved August 14, 2023, from: https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/third-party-payments-policy.html
  24. Ibid
  25. Government of Canada. (July 19, 2023). Scientific Research and Experimental Development (SR&ED) tax incentives: Calculate qualified expenditures. Retrieved August 16, 2023, from: https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/sred-claim/qualified-expenditures.html
  26. Government of Canada. (July 19, 2023). Scientific Research and Experimental Development (SR&ED) tax incentives: Calculate qualified expenditures. Retrieved August 16, 2023, from: https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/sred-claim/qualified-expenditures.html
  27. Government of Canada. (December 18, 2014). Assistance and Contract Payments Policy: Assistance received or receivable by a non-arms length party. Retrieved August 15, 2023, from: https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/assistance-contract-payments-policy.html
  28. Ibid
  29. Government of Canada. (March 30, 2022). Contract Expenditures for SR&ED Performed on Behalf of a Claimant Policy. Retrieved August 16, 2023, from: https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/contract-expenditures-performed-on-behalf-a-claimant-policy.html
  30. Government of Canada. (December 18, 2014). Total Qualified SR&ED Expenditures for Investment Tax Credit Purposes Policy. Retrieved August 16, 2023, from: https://www.canada.ca/en/revenue-agency/services/scientific-research-experimental-development-tax-incentive-program/total-qualified-expenditures-investment-tax-credit-purposes-policy.html
  31. Ibid
  32. Ibid
  33. Ibid

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