THIS CASE STUDY EXEMPLIFIES THE APPLICATION OF KEY LEGISLATIVE REQUIREMENTS FOR QUALIFYING SR&ED ACTIVITIES AS THEY APPLY TO RELEVANT ACTIVITIES IN THE TRANSPORTATION INDUSTRY.
BUSINESS SCENARIO
Earhart Engineering is a widely renowned engineering company specializing in modern building of transportation methods, systems and equipment.
Dedicated to being one step ahead of its competitors, Earhart Engineering proposed an SR&ED plan to create the ‘Self-e,’ an electric, self-operating vehicle/aircraft. Earhart’s main objective was to develop a legal transportation vehicle/aircraft using battery technology that would allow it to travel up to 500 miles without requiring a recharge, while being completely machine operated.
To qualify for the Scientific Research and Experimental Development Tax Incentive Program, Earhart Engineering had to make sure its activities met the definition of “scientific research and experimental development” in subsection 248(1) of the Income Tax Act (see Commentary below). After self-assessing, Earhart Engineering declared the following experiments as SR&ED work.
EARHART ENGINEERING’S ELIGIBLE SR&ED ACTIVITIES
Design and development of a series of prototypes to achieve the technical objectives (design of the Self-e vehicle/aircraft).
The hypothesis for this SR&ED activity was that designing, testing and evaluating various concepts would contribute to a more efficient and effective prototype testing phase.
After two years of design and experimentation, Earhart Engineering concluded that its theoretical design experiments showed that such designs were feasible but needed to be prototyped and fully tested to prove the hypothesis.
Trials and analysis of data to achieve results that can be reproduced to a satisfactory standard and to test the hypothesis (prototype development and testing of the Self-e vehicle/aircraft).
Earhart Engineering’s hypothesis for this experiment was that developing and implementing the various design components would allow refinement and tweaking of the final product to achieve the technical objectives.
After two years of trial and error, Earhart Engineering had created a vehicle capable of performing the main functions of the ‘Self-e’ but was below the company’s expectations overall. Earhart Engineering concluded that it was on the right track, and that it would continue to work on improving its design until it met its targeted performance criteria.
Background research to evaluate current knowledge gaps and determine feasibility (background research for the design of the Self-e).
Earhart Engineering engaged in background research for two years which included activities such as literature search and review, consultation with industry professionals and potential customers, and preliminary equipment and resources review with respect to capacity, performance and suitability for the project.
These specific background research activities qualified as SR&ED because they assisted in identifying the key elements of the research project.
Ongoing analysis of customer or user feedback to improve the prototype design (feedback SR&ED of the Self-e).
Feedback research and development work for the Self-e included ongoing analysis and testing to improve the efficiency and safety of the project, continuous development and modification, and commercial analysis and functionality of review.
Earhart Engineering believed these activities were necessary to evaluate the performance capabilities of the new design in the field and to improve any flaws in the design, therefore qualifying as SR&ED.
COMMENTARY
To qualify, the work must meet the following definition of “scientific research and experimental development” (SR&ED), as defined in subsection 248(1) of the Income Tax Act.
“Scientific research and experimental development” means systematic investigation or search that is carried out in a field of science or technology by means of experiment or analysis and that is:
(a) basic research, namely work undertaken for the advancement of scientific knowledge without a specific practical application in view;
(b) applied research, namely work undertaken for the advancement of scientific knowledge with a specific practical application in view; or
(c) experimental development, namely, work undertaken for the purpose of achieving technological advancement for the purpose of creating new, or improving existing, materials, devices, products or processes, including incremental improvements thereto;
and, in applying this definition in respect of a taxpayer, includes:
(d) work undertaken by or on behalf of the taxpayer with respect to engineering, design, operations research, mathematical analysis, computer programming, data collection, testing or psychological research, where the work is commensurate with the needs, and directly in support, of work described in paragraph (a), (b), or (c) that is undertaken in Canada by or on behalf of the taxpayer.
WHAT RECORDS AND SPECIFIC DOCUMENTATION DID EARHART ENGINEERING KEEP?
Similar to any tax credit or deduction, Earhart Engineering had to save business records that outlined what it did in its SR&ED activities, including experimental activities and documents to prove that the work took place in a systematic manner. Earhart Engineering saved the following documentation:
- Literature review
- Background research
- Meeting notes or minutes or progress reports
- Project records / laboratory notes
- Conceptual sketches
- Design drawings
- Photographs / videos of various parts or components
By having these records on file, Earhart Engineering confirmed that it was “compliance ready” — meaning if it was audited by the CRA, it could present documentation that illustrated the progression of its SR&ED activity, ultimately proving its SR&ED eligibility.
