Précis: This decision is similar to the Concept Danat case blogged recently on this site, with the exception that the numbers involved are bigger and the work was being done for a third party customer. The taxpayer claimed SRED expense in connection with 4 specific projects. Two projects were abandoned before trial. The Court found that 2/3 of the projects described as Matteo lathes involved normal engineering and lacked the innovation necessary to qualify for SRED treatment while the remaining 1/3 did qualify for SRED treatment. The fourth project did have the requisite element of innovation and the appeal was allowed in in full respect of it. There was no order as to costs in light of the mixed success. Nevertheless it was largely a good day for the taxpayer which made, I understand, about a 70% recovery of the amounts it chose to take to trial.
A & D Precision Limited v. R. – TCC: Taxpayer achieves mixed success in SRED claimsREAD MORE »