Expenditure Limit Rate Reduction: A Guide for Businesses

Expenditure limit rate reduction is a crucial concept for corporations in Canada, particularly those involved in Scientific Research and Experimental Development (SR&ED). It refers to the scaling down of tax credits a corporation can claim based on its expenditure limits, which are determined by its taxable income and taxable capital. 

It is important to understand this concept due to its direct impact on the potential benefits corporations can derive from SR&ED tax credit incentives.

Overview of SR&ED Tax Incentive Program

Canada’s SR&ED Tax Incentive Program is a federal tax incentive designed to encourage businesses of all sizes, including corporations, partnerships, and trusts, to SR&ED in Canada. The initiative is administered by the Canada Revenue Agency (CRA), aiming to stimulate innovation, improve productivity, and foster global competitiveness. The program provides either an Investment Tax Credit (ITC) that can be used to reduce tax payable or a refundable credit that can be paid directly to the applicant. This is where understanding the expenditure limit rate reduction becomes essential to maximize economic benefit.

Explanation of Expenditure Limit for CCPCs vs. non-CCPCs

The expenditure limit rate reduction varies for Canadian Controlled Private Corporations (CCPCs) and organizations that are not CCPCs.

CCPCs that qualify for the SR&ED tax incentive program can claim a refundable ITC at the enhanced rate of 35% on the first $3 million of qualifying expenditures. However, the expendable limit is reduced when a CCPC’s taxable income in the prior year exceeds $500,000 or when its taxable capital exceeds $10 million in the previous year.

For organizations that are not CCPCs, the tax credit is non-refundable and claimed at a basic rate of 15% on qualifying expenditures. This category includes public corporations, foreign corporations, and private corporations controlled by a public or foreign corporation. Understanding these differences and the specifics of the expenditure limit can help corporations strategize their R&D activities and optimize their tax incentives. To learn more about the types of corporations recognized by the Canadian Government, click here.

Phasing Out of Expenditure Limit Based on Taxable Capital

An interesting nuance of expenditure limit rate reduction is its approach to taxable capital. As a CCPC’s taxable capital begins to exceed $10 million, its expenditure limit starts to phase out. The limit reduces linearly, eventually hitting zero when the taxable capital reaches $50 million. This phase-out is designed to curb the incentives for larger corporations, shifting the benefits towards smaller innovators.

For non-CCPCs, there is no expenditure limit phase-out based on taxable capital. They adhere to a fixed rate of 15%, regardless of the size of their taxable capital. This discrepancy brings a different set of strategic considerations for CCPCs and non-CCPCs.

Calculating the Rate Limit

Taking a practical approach helps simplify the concept of expenditure limit rate reduction. Let’s consider two examples: a CCPC with taxable capital totalling $30 million and a non-CCPC with the same amount.


For a CCPC, once its taxable capital exceeds the $10 million threshold, the expenditure limit begins to reduce accordingly. Specifically, for a CCPC with taxable capital totalling $30 million, the calculation involves the taxable capital exceeding $10 million — which is $20 million in this case — and applying the reduction rate of 5% per each million dollars of excess. This calculation leads to a reduction that equals the entire expenditure limit of $3 million, essentially nullifying the enhanced credit rate. Therefore, despite initially having a $3 million expenditure limit, the CCPC faces a reduction that completely phases out its limit due to its higher taxable capital level, impacting its eligibility for the enhanced 35% tax credit on eligible SR&ED expenditures.


In contrast, the situation presents differently for a non-CCPC, where the phase-out based on taxable capital does not apply. Regardless of having the same $30 million in taxable capital as the CCPC, a non-CCPC does not experience any reduction in its expenditure limit. The non-CCPC continuously benefits from a basic 15% credit rate on all its qualifying expenditures, unaffected by the size of its taxable capital.

Allocation of Limit Among Associated Corporations

For cases where associated corporations are conducting SR&ED activities, allocation of the expenditure limit becomes a necessity. The way the CRA outlines this process considers the entire group’s taxable income and taxable capital in the prior year. The group as a whole is subject to the same expenditure limit ($3 million), split among the corporations in a manner that will provide the maximum potential input tax credits.

This shared pool requires strategic planning within associated corporations, ensuring the most effective distribution. This could involve allocating more to corporations with larger qualifying expenditures or those with significant R&D activities, for instance.

Impact of Expenditure Limit Rate Reduction on Tax Policy and Organizations

Understanding and navigating expenditure limit rate reduction has profound implications for both tax policy and corporate finance strategy. For policymakers, it presents a balancing act between encouraging innovation and ensuring fair tax practices. For corporate entities, comprehending the expenditure limit and its calculated reduction is vital for effective strategic tax planning and maximizing the potential benefits from the SR&ED program.

Effectively, organizations must balance their taxable income, capital, and R&D activities to avail of the maximum incentives without unwittingly exceeding their limits. Ignorance of these parameters can be costly, leaving corporations with lower-than-expected tax credits. Hence, it’s imperative that organizations grasp the essence of expenditure limit rate reduction.

Expert Guidance by G6 Consulting

Navigating the SR&ED program’s intricacies, especially expenditure limit rate reduction can seem daunting. Fortunately, specialized assistance can transform this challenge into an opportunity for your business. At G6 Consulting, with over 12 years of experience and a history of thousands of successful claims, we excel at helping businesses like yours maximize their SR&ED tax credits.

Our full-service approach to SR&ED consulting means that we handle everything: building your claim, completing paperwork, and submissions, and even providing robust audit defence when necessary. Our expertise is not just in recognizing qualifying activities, but also in strategically managing expenditure limits to your best advantage. We only get paid after your claim is fully approved and paid out, which aligns our success with your financial gains.

Whether you are a start-up, an established SME, or a large corporation, our team at G6 Consulting can identify and optimize R&D tax credit opportunities for your company. We take pride in offering a personalized, customer-centric service, as testified by numerous satisfied clients who have benefitted significantly from our expertise.

Don’t let the complexities of expenditure limit rate reductions impede your innovation journey. Contact G6 Consulting for a free consultation, and let’s ensure your business’s R&D tax credits are fully maximized. Our meticulous approach and commitment to client success make us the clear choice for businesses looking to advance through the SR&ED program.

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