Here’s an article from today. It’s about the declining
payouts under the SR&ED program. http://www.obj.ca/Technology/2016-11-22/article-4690924/Feds-%26lsquo%3Bclawed-back%26rsquo%3B-$4.2B-in-SR%26amp%3BED-credits,-Ottawa-based-tech-group-says/1.
The article speculates on why this is so. My own opinion is that it largely has
to do with the increased number of audits. I don’t think that auditors are any
tougher on the claims than they were before CRA began a few years ago to select
so many more to audit. The problem is that a significant percentage of claims are
adjusted downwards whether 10% are audited or 60% are. If 50% of audited claims,
for example, are reduced and only 10% are audited, then 5% of all claims will
be reduced. If 60% are audited, then 30% would be reduced. It’s simple
arithmetic.
The two main reasons for CRA not accepting a claim
are, in my experience, lack of documentation (which the article mentions and
also discussed at https://gordonfeil.blogspot.ca/2016/11/the-5-sr-questions.html)
and the RTA not recognizing the technical uncertainties of the claimed project,
which I discussed at https://gordonfeil.blogspot.ca/2016/11/did-your-sr-claim-invite-cra-to-door.html.
There are some reviewers who think that each step of the SRED process should of
itself be SRED. Sometimes an RTA does not take into consideration the
Scientific and Technological Uncertainty present in the overall project
objective and bases their assessment, instead, on the particular technical
steps taken to resolve the uncertainty. Justice Jorré discussed this approach
in expressing his ruling in the case of Les
Abeilles Service de Conditionnement Inc. v. The Queen, in which he stated
that a project must be considered as a whole rather than looking at each
individual step separately.
No comments :
Post a Comment