Current Issues

Hot SR&ED Issues

Issues currently in contention with CRA, and where the numbers have been heading.

SR&ED by Medical Professional Corporations (MPCs)

During the past five years the medical and dental professions have faced specific challenges claiming SR&ED tax credits. The table below tracks the issues in contention with CRA, 2016–2021.

Issue20212020201920172016
1. AFP / APP funding as assistance — portion related to SR&ED?PDF · VideoPDF · VideoPDF · VideoPDF · VideoPDF · Video
2. Directly engaged — doctor vs. MPC? ✓ResolvedPDF · VideoPDF · VideoPDF · VideoPDF · VideoPDF · Video
3. Contract eligibility tips—PDF—PDF · Video—
4. Proving input on protocolsPDF · Video—PDFPDF · Video—
5. Speed of objection responses > 4 years ✓ResolvedPDF—PDFPDF · Video—
Illustrating an eligible SR&ED project by a Medical Professional Corporation: Dr. Andre Lamy MPC — Tax Court of Canada judgment. See the full case entry on the Tax Cases page (2020 TCC 61).
SR&ED Tax Credit Statistics

Claims and investment tax credits by fiscal year, 2007 to present. Figures from FY2022 onward come from CRA's own published statistics, distinguishing claims filed from claims processed, and ITCs claimed from ITCs allowed; earlier years reflect the CRA Redbook, which tracked claims processed and ITCs claimed only.

YearClaims filedClaims processedITCs claimedITCs allowedVariance — claimsVariance — ITCs
CRA Official Annual Program Statistics · FY2022–FY2026
Mar 202624,16023,677$4.9B$4.6B+6.2%+4.3%
Mar 202522,75822,738$4.7B$4.5B+5.7%+6.8%
Mar 202421,52421,537$4.4B$4.2B+5.2%+15.8%
Mar 202320,46420,079$3.8B$3.6B+0.6%+11.8%
Mar 202220,33220,317$3.4B$3.3B——
CRA Redbook (historical) · claims processed & ITCs claimed only
2021*—19,783$4,277,011—1.0%40.4%
2020—19,595$3,046,754—-0.2%-5.4%
2019—19,632$3,219,591—-1.1%1.3%
2018—19,855$3,177,717—-4.8%-1.7%
2017—20,867$3,231,128—-8.6%-18.8%
2016—22,839$3,979,168—-6.0%-5.5%
2015—24,302$4,211,057—-4.0%-3.5%
2014—25,312$4,361,819—-11.2%16.5%
2010—28,518$3,743,200—27.5%-8.3%
2007—22,370$4,081,256———

*2021 Redbook figures reflect 11 months. The Mar 2022 row is not directly comparable to 2021 above it — CRA changed from calendar-year Redbook reporting to fiscal-year (Apr–Mar) reporting with the filed/processed and claimed/allowed distinctions shown above, so no variance is shown across that boundary. 2014–2020 change: claims -22.6%, ITCs -30.1%. 2014–2021 change: claims -21.9%, ITCs -1.9%. Sources: CRA Redbook (2007–2021); CRA Annual Program Statistics (FY2022–FY2026).

Funding has grown roughly 50% since FY2022, when total ITCs claimed were $3.4B. Acceptance rates have held steady at 90–91% accepted as filed across FY2022–FY2026. Note the retroactive Budget changes effective for tax years after Dec 16, 2024 — CCPCs now qualify for the 35% refundable ITC more broadly, capital items are reinstated as eligible costs, and the expenditure limit for the 35% refundable credit rose from $3M to $6M — expect these to push both claim counts and average claim size higher in FY2027 reporting. Analysis and discussion by David Sabina & Russ Roberts — see the Webcasts archive for the full session.