SRED: Systematic Uncertainty

One of the most frequent faults CRA’s SR&ED reviewers find in a claim during an on-site review is that the project contained technical uncertainties rather than technological uncertainties. The difference has to do with whether the uncertainty is an obstacle that can be resolved by technology (knowledge) that is at the taxpayer’s disposal. I have frequently been in reviews where the RTA has insisted that the project’s advancement was simply achieved by merging together already existing technologies, not acknowledging that the integration of technologies that had been used in other contexts involved uncertainty over how to make them work successfully together in the current project. Yet, often systematic uncertainty arises, and it is not clear how to get technological components to do what the claimant needs them to do when they are interacting together, with the result that systematic investigation of the problem is used to develop experiments to resolve the uncertainties. I don’t doubt that according to the law, SR&ED is being done in such cases, but it does not always seem easy for an RTA to get it.