Scitax Advisory Partners LP
Canada
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SR&ED Court Cases and Jurisprudence

Below is an archive of court rulings which we feel have been particularly significant in shaping the interpretation of the SR&ED related provisions of Canada's Income Tax Act. We believe that these cases provide useful guidance with respect to what types of R&D activities can be claimed, the expenditures that qualify to attract SR&ED benefits, and the benefit rates that apply to various types of business structures. This is not intended to be a complete list of all SR&ED related cases.

Simon Ribbans Photography Inc. v The King Tax Court of Canada October 2025 Tax Court of Canada Paveit Construction Inc. v. The King in Tax Court Canada of Canada September 2025 Tax Court of Canada Vortex Energy Services Ltd. v. The King in Tax Court Canada of Canada May 2025 Tax Court of Canada DAZZM Inc. v. The King in Tax Court Canada of Canada October 2024 Tax Court of Canada Canafric Inc. v. The King in Tax Court Canada of Canada July 2023 Tax Court of Canada Buehler Versatile Inc. v. The King in Tax Court Canada of Canada February 2023 Tax Court of Canada JEC Distributors Inc. v. The King in Tax Court Canada of Canada December 2022 Tax Court of Canada CAE Inc. in Federal Court of Appeal October 2022 Federal Court of Appeal Dave’s Diesel Inc. v. The Queen in Tax Court Canada of Canada June 2022 Tax Court of Canada CAE Inc. Factum to Canadian Federal Court of Appeal March 2022 Federal Court of Appeal Airzone One Ltd. in Tax Court Canada February 2022 Tax Court of Canada CAE Inc. in Tax Court Canada September 2021 Federal Court of Appeal Kam-Press Metal Products Ltd. in Federal Court of Appeal April 2021 Federal Court of Appeal Allegro Wireless Canada Inc v. The Queen in Tax Court of Canada March 2021 Tax Court of Canada Indusol Industrial Control Ltd. v. The Queen in Tax Court of Canada September 2020 Tax Court of Canada Andre Lamy Medicine Professional Corporation v. The Queen in Tax Court of Canada July 2020 Tax Court of Canada National R&D Inc. in Tax Court of Canada July 2020 Tax Court of Canada Béton mobile du Québec Inc. in Tax Court of Canada December 2019 Tax Court of Canada Kam-Press Metal Products Ltd. in Tax Court Canada October 2019 Tax Court of Canada A&D Precision Limited in Tax Court of Canada February 2019 Tax Court of Canada Dock Edge Inc. in Tax Court of Canada January 2019 Tax Court of Canada Borealis Geopower Inc. in Tax Court of Canada September 2018 Tax Court of Canada Aeronautic Development Corp. in Tax Court of Canada April 2018 Tax Court of Canada Westsource Group Holdings in Federal Court of Appeal March 2018 Federal Court of Appeal Akanda Corp in Tax Court of Canada Feb 2018 Tax Court of Canada D. Nagel in Tax Court of Canada Feb 2018 Tax Court of Canada Mac & Mac Hydrodemolition Services in Tax Court of Canada December 2017 Tax Court of Canada Lehigh Hanson Materials in Tax Court of Canada Oct 2017 Tax Court of Canada Robotx Solutions Inc. in Tax Court of Canada May 2017 Tax Court of Canada Les éléments chauffants Tempora inc / Maged Elhami and Shady Elhami in Court of Quebec Quebec Court Formadrain Inc. in Tax Court of Canada March 2017 Tax Court of Canada Aeronautic Development Corp. in Tax Court of Canada January 2017 Tax Court of Canada Life Choice Ltd. in Tax Court of Canada January 2017 Tax Court of Canada Westsource Group Holdings Inc. in Tax Court of Canada January 2017 Tax Court of Canada Joel Theatrical Rigging in TCC January 2017 Tax Court of Canada Easy Way Cattle Oilers Ltd. in Federal Court of Appeal November 2016 Federal Court of Appeal Oldcastle Building Products Canada Inc. in Tax Court of Canada Aug 2016 Tax Court of Canada AFD Petroleum Ltd. in Federal Court of Canada May 2016 Federal Court A & D Precision Ltd. in Tax Court Canada May 2016 Tax Court of Canada Recherches Novalia Inc in Tax Court Canada April 2016 Tax Court of Canada McGillivray Restaurant Ltd. in FCA March 2016 (Meaning of Defacto Control) Federal Court of Appeal ACSIS EHR (Electronic Health Record) Inc. AWARD OF LEGAL COSTS in Tax Court of Canada February 2016 Tax Court of Canada Emotion Picture Studios Inc. in Tax Court Canada December 2015 Tax Court of Canada 2037625 Ontario Inc. (Formerly ITC Invoice to Cash Inc.) in Tax Court Canada October 2015 Tax Court of Canada Fio Corporation in Federal Court of Appeal October 2015 Federal Court of Appeal ACSIS EHR (Electronic Health Record) Inc. MAIN ACTION SR&ED in Tax Court of Canada October 2015 Tax Court of Canada Easy Way Cattle Oilers Ltd. in Tax Court Canada Aug 2015 Tax Court of Canada R&D Pro-Innovation Inc. in Tax Court Canada July 2015 Tax Court of Canada Highweb & Page Group Inc. in Tax Court Canada June 2015 Tax Court of Canada 6379249 Canada Inc. in Tax Court Canada March 2015 Tax Court of Canada Hypercube Inc. in Tax Court Canada March 2015 Tax Court of Canada HLP Solutions Inc. in Tax Court Canada (court order re CRA expert witness) February 2015 Tax Court of Canada Feedlot Health Management Services Ltd. in Tax Court Canada February 2015 Tax Court of Canada Abeilles Inc. in Tax Court Canada October 2014 Tax Court of Canada Immunovaccine Technologies Inc. in Federal Court of Appeal September 2014 Federal Court of Appeal Fio Corporation in Tax Court Canada February 2014 (Implied Undertakings Motion Only) Tax Court of Canada CalAmp Wireless Networks Inc. in Tax Court Canada June 2013 Tax Court of Canada Bagtech in Federal Court of Appeal June 2013 Federal Court of Appeal Immunovaccine Technologies Inc. in Tax Court Canada April 2013 Tax Court of Canada Lyrtech RD in Tax Court Canada January 2013 Tax Court of Canada 1726437 ONTARIO Inc. o/a Airmax Technologies in Tax Court Canada October 2012 Tax Court of Canada Laboratoire Du-Var Inc. in Tax Court Canada July 2012 Tax Court of Canada Murray Arlin Dentistry PC in Tax Court Canada April 2012 Tax Court of Canada Bagtech in Tax Court Canada April 2012 Tax Court of Canada Jentel Manufacturing in Federal Court of Appeal December 2011 Federal Court of Appeal Soneil International Ltd. in Tax Court Canada August 2011 Tax Court of Canada Jentel Manufacturing in Tax Court Canada June 2010 Tax Court of Canada Alberta Court of Queen’s Bench and Provincial Court Alberta decisions in Global Enviro Inc. and Ian George McIntyre Other Giovanni Tozzi in Tax Court Canada August 2012 (nil assessment) Tax Court of Canada One Source Metal in Tax Court Canada July 2009 (Use of prescribed T661 forms) Tax Court of Canada Union Carbide Corporation in U.S. Tax Court June 2010 Tax Court of Canada Zeuter Development Corporation in Tax Court Canada October 2006 Tax Court of Canada Blue Wave Seafoods Inc. in Tax Court Canada August 2004 Tax Court of Canada Auray-Blais in Tax Court Canada January 2003 Tax Court of Canada CW Agencies in Federal Court of Appeal December 2001 Federal Court of Appeal CW Agencies in Tax Court Canada August 2000 Tax Court of Canada Tigney Technology Inc. in Federal Court of Appeal February 2000 Federal Court of Appeal LGL Ltd. v R Tax Court of Canada FCA 2000 Federal Court of Appeal Rainbow Pipe Line Co. in Tax Court Canada September 1999 Tax Court of Canada Com Dev Ltd. in Tax Court Canada March 1999 Tax Court of Canada Hun-Medipharma in Tax Court Canada January 1999 Tax Court of Canada LGL Ltd. v R Tax Court of Canada TCC 1999 Tax Court of Canada RIS Christie in Federal Court of Appeal December 1998 Federal Court of Appeal Data Kinetics Ltd. in Tax Court Canada July 1998 Tax Court of Canada 116736 Canada Inc. in Tax Court Canada June 1998 Tax Court of Canada Northwest Hydraulic Consultants Ltd. in Tax Court Canada May 1998 Tax Court of Canada Consoltex Inc. in Tax Court Canada March 1997 Tax Court of Canada Tigney Technology Inc. in Tax Court Canada 1997 Tax Court of Canada CCLC Technologies Inc. in Federal Court of Appeal September 1996 Federal Court of Appeal RIS Christie in Tax Court of Canada August 1996 Tax Court of Canada CCLC Technologies Inc. in Federal Court November 1995 Federal Court Highland Foundry Ltd. in Tax Court Canada August 1994 Tax Court of Canada Canalerta Technologies Inc. in Tax Court Canada 1992 Tax Court of Canada Cultures Laflamme (1984) Inc. in Tax Court Canada June 1992 Tax Court of Canada Revelations Research Ltd. in Tax Court Canada 1991 Tax Court of Canada Ben Martens in Tax Court Canada May 1988 (nil assessment) Tax Court of Canada Sass Manufacturing Ltd. in Tax Court Canada 1988 Tax Court of Canada Radio Engineering Products Limited in DTC January 1973