Credit Comparison

Canada United States United Kingdom France
Nature of Admissible Activity
  • Experimental Development
  • Discovery, technological advancement (technological uncertainty)
  • Process of Experimentation (evidence)
Principles of the Program
  • Expenditures
  • Variation of expenditures (base amount)
  • Volume
  • Volume of expenditures
Principles of the Claim
  • Per project with report submission
  • Per division without report submission
  • Per project with option of report submission
  • Per project without report submission
Statutes of limitations (Filing Deadlines)
  • 18 months after fiscal year end
  • 3 years after the filing date
  • 2 years for the refundable tax credit
  • One year
Type of Fiscal incentive
Definition of SME
  • Canadian Controlled Private Corporation CCPC
  • with the Small Business Deduction i.e. Taxable Income of less than $400,000
  • Entity with 3 fiscal periods of R&D expenditures and Sales between 1984 et 1988
  • New SME friendly program introduced in December 2006
  • Less than 250 (500)1 employees and
  • Sales less than €50 M (€100 M)1 or
  • Assets less than €43 M (€86 M)1
  • N/A
SME
Tax Credit (ITC’s) of 35% refundable on the 1st $ 3M of expenditures Special Measures in the calculation  of the base amount for start ups (after 1989)
  • Super Deduction (SD) of 150% (175%)1 or
  • Tax credit of 24% limited to the amount income tax paid on salaries
  • Tax Credit of 30% on expenditures up to €100M and Tax credit of 5% on expenditures over €100M
  • Tax credit 50% if first claim and 40% for the 2nd year
Large Corporation
Tax Credit of 20% deferrable Tax credit deferrable of 20% (limited in reality to 10%) Super Deduction of 125% (130%)1
Canada United States United Kingdom France
Refundable
Yes, for SME’s only with a maximum of 1,05 M $ per year No, applicable only against income taxes paid Yes, for SME’s that renounce the SD at 150% (175%)1 in favor of a tax credit refundable and limited to 24% of tax paid on salaries Yes, after having carried forward the credits for 3 years except for businesses of less than 5 years old that are entitled to an immediate refund.
Carry back and carry forward of unused portion of the Tax Credit
ITC’s carried back 3 years and carried forward 20 years Tax Credit carry-back of 1 year and carry-forward of 20 years SD carried forward indefinitely -
Deductibility of other Tax Credits
ITC’s from 8 provinces must be deducted from expenditures Tax Credits from 31 states could be accumulated from Federal tax credits - -
Ceiling of Incentives
No, except for the 1,05 M $ refundable per year No No, except for the tax credit of 24% limited to the amount of income tax paid on salaries Maximum of €10M per year for 2006, €16M for 2007, none since January 2008
Responsible Authority
Canada Revenue Agency (CRA) Internal Revenue Service (IRS) Inland Revenue Ministère de l’économie, des finances et de l’industrie Direction générale des impôts
Review Officer
Auditor Agent Inspector Contrôleur des impôts
Legal Designation and Acronym
Scientific Research and Experimental Development (SR&ED) Research Tax Credit (RTC) Alternative Incremental Research Tax Credit New Alternative Simplified Credit R&D Tax Credits Crédit d’impôt recherche (CIR)
Canada United States United Kingdom France
Qualifying Expenditures
Salaries
Yes Yes Yes Yes
Matérial
Yes Yes Yes No
Sub- Contractors
Yes Yes, but at 65% Yes but at 65% for SME  and according to certain regulations for Large Corporations Yes
Overhead Expenses
Yes, with the option of using 65% of R&D salaries No No Yes , (75% of salaries)
Patent Litigation and Defense
No Yes, according to certain rules No Yes
Veille technologique
- - - Oui
Property
Yes, except buildings(admissible for ITC’s according to 2 rules of utilization) No No Yes (amortization of property for R-D )
Rules on Intellectual Property
Yes - Yes for SME’s only -
Taxation on ITC’s
Yes, on the following year Yes on federal tax credits for current year but State tax credits not generally imposable Yes Yes
Significant Improvements
1996
2002
2008
 1999
2006
 2002
2004
 2004
2005
2006
2008
Rate of effective assistance
From 20% to35% From 5% to10%
  • TC SME 24%
  • SD SME 9.5% (50% x 19%)
  • SD LC 7.5% (25% x 30%)
 From 30% to 50%
1 Numbers in bracket ( ) will have effect from a date to be appointed by treasury order

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