

Quick Answer
Possibly — but not yet with certainty, because this is a proposed measure, not enacted law. Under draft legislation released by the Department of Finance on January 29, 2026, a Canadian business may be able to deduct 100% of the cost of an eligible manufacturing or processing (M&P) building in the first year it is used, instead of writing it off slowly under the normal capital cost allowance rules. To qualify, the building generally must be acquired on or after November 4, 2025, be first used for M&P before 2030, and have at least 90% of its floor space used to manufacture or process goods for sale or lease. The full 100% rate phases down for buildings first used in 2030 and later, and a recapture rule can claw back the deduction if the building’s use changes within 10 years. Because the rules are still in draft form and the eligibility tests are strict, confirm your situation with a qualified Canadian accountant before relying on this deduction.
— Why Ontario Manufacturers Are Suddenly Asking About This
If you run a manufacturing or processing business, you may have heard that you can deduct the entire cost of a new factory building in a single year. One client put it plainly — “Can I really write off my whole new plant this year, or is that just talk?”
The honest answer: the federal government has proposed exactly that for eligible manufacturing buildings, but it is still a proposal with strict conditions. This guide covers what it does, who it is for, the tests that trip people up, and what to do now. For the bigger picture, see our overview of what Budget 2025 means for Canadian businesses.
— What “Immediate Expensing” Actually Means (In Plain English)
Normally the Income Tax Act does not let you deduct a building’s full cost right away. You claim it gradually through capital cost allowance (CCA) — the tax system’s version of depreciation, deducting a set percentage of the remaining value each year. Most buildings sit in CCA Class 1 at 4% per year on a declining-balance basis; manufacturing buildings can reach 10% with a separate-class election, but fully deducting the cost still takes decades.
The proposed measure changes that for eligible manufacturing or processing (M&P) buildings — structures used to make or process goods for sale or lease. It would allow an immediate 100% first-year deduction and waive the usual “half-year rule” that limits a first-year claim. Ottawa brands this and related changes the “Productivity Super-Deduction.” It helps to know how Canadian corporate tax rates work to see how a large deduction affects your bill.
— Is This Actually Law Yet? The Honest Status
This matters for real decisions. The draft legislation went through a consultation period that closed in February 2026, and the measure was deliberately separated from Bill C-15, the bill that implemented many other Budget 2025 changes (including immediate expensing for manufacturing equipment). The government’s 2026 federal economic update reaffirmed its intention to proceed, but until a bill passes, the details are not final.
What this means for you: plan around the proposal, but do not treat the deduction as guaranteed when making an irreversible decision. Tracking this is the kind of thing in our roundup of what small businesses should watch in 2026.
— Quick Start: Pick Your Path
Not every business is in scope. Use this quick check to see where you likely stand:
A building that is mostly offices, retail, or warehousing likely fails the manufacturing-use tests, so immediate expensing generally would not apply.
| Condition | What it requires | Common fail |
|---|---|---|
| Acquisition date | Building acquired on or after November 4, 2025 | Bought or contracted before Budget Day 2025 |
| First use timing | First used for M&P before 2030 for the full 100% rate | Construction runs past 2029, triggering the phase-out |
| 90% floor-space test | At least 90% of floor space used to make or process goods for sale or lease | Too much office, retail, or finished-goods storage space |
| Ownership & use | Owned and used by the claiming corporation in an active business | Held passively or in a structure that breaks the test |
| Property history | Not previously owned by you or a non-arm’s-length person; not a tax-deferred rollover | Acquired from a related party or via a rollover |
— Who Qualifies: The 90% Floor-Space Test and Eligible Property
The conditions are specific, and missing any one can disqualify the deduction. Based on the Department of Finance draft proposals, an eligible building generally must: be acquired on or after November 4, 2025 (Budget Day); be first used for M&P before 2030 for the full 100% rate; and have at least 90% of its floor space used to manufacture or process goods for sale or lease — which is why office, retail, and storage space can be a problem.
Eligible additions or alterations can also qualify, so an expansion is not automatically excluded. Used property generally only qualifies if it was not previously owned by you or a non-arm’s-length person and was not transferred on a tax-deferred rollover basis, and it must be owned and used by the claiming corporation in an active business.
The 100% rate is time-limited. It applies in full only if the building is first used for M&P before 2030, then steps down: 75% for 2030 or 2031, 55% for 2032 or 2033, and no enhanced rate after 2033. The year your building actually becomes operational — not when you start planning — determines your rate.
— Old Rules vs Proposed Rules: What Changes for Your Return
The practical difference is about timing of the deduction, not the total amount you can eventually claim.
| Feature | Normal CCA (Class 1 building) | Proposed immediate expensing |
|---|---|---|
| First-year deduction | Typically 4%, or up to 10% with a separate-class election | 100% if first used for M&P before 2030 |
| Half-year rule | Generally applies, reducing the first-year claim | Waived for eligible buildings |
| Time to fully deduct | Often decades on a declining-balance basis | Entire cost in year one (subject to phase-out) |
| Total lifetime deduction | Full cost of the building | Same full cost — only the timing changes |
| Legislative status | Long-standing law | Proposed; draft legislation as of early 2026 |
Illustrative example only: a corporation builds a $4 million eligible processing plant operational in 2026. Under the proposal it could deduct the full $4 million that year. A deduction that large can create a non-capital loss, generally carried back 3 years or forward 20 years against other income. Actual outcomes depend on your facts, your tax rate, and the final legislation. For Ontario rate context, see the 2026 Ontario small business tax rate.
— Step-by-Step: How the Deduction Would Be Claimed
If the measure is enacted broadly as drafted, claiming it would generally look like this:
- 1Confirm M&P useConfirm the building is genuinely used for manufacturing or processing and can meet the 90% floor-space test, ideally before you finalize the design or purchase.
- 2Allocate land vs buildingReasonably allocate the purchase price between land and building if bought together, since only the building portion can qualify.
- 3Check timingConfirm the acquisition date is on or after November 4, 2025, and project when the building becomes available for use, because that year sets your rate.
- 4File the election on timeFile the required separate-class CCA election on time. The CRA generally does not accept late-filed elections, and for corporations the window is often around six months after the tax year-end.
- 5Claim on the T2Claim the deduction on the corporate T2 return for the year the building becomes available for use, prorated for a short tax year. Our guide on prorating Ontario corporate tax for a short year explains how short years affect claims.
- 6Monitor for 10 yearsMonitor the building’s use for the next 10 calendar years, because a change in use can trigger recapture.
— Common Mistakes That Could Cost You the Deduction
- →Treating the measure as settled law. It is currently a proposal, so basing an irreversible decision on it without advice is risky.
- →Failing the 90% floor-space test because too much of the building is used for offices, sales, or storing finished goods.
- →Missing the separate-class election deadline. A late election generally cannot be fixed, and the deduction can be lost entirely.
- →Mis-allocating cost between land and building. Land never qualifies for CCA, so an unreasonable split can be challenged.
- →Ignoring the recapture window and changing the building’s use within 10 years, which can pull part of the deduction back into income.
- →Confusing this buildings measure with the separate immediate expensing for machinery and equipment, which has different rules and was handled in Bill C-15.
- →Assuming an expansion does not count. Eligible additions and alterations can qualify, so check rather than assume. Manufacturers often miss stacking opportunities; see our piece on stacking SR&ED incentives for manufacturers.
— Frequently Asked Questions
Can I really deduct 100% of my new factory building this year?
Is this immediate expensing rule actually law yet, or could it still change?
Does a renovation or addition to my existing plant qualify, or only a brand-new building?
What happens if I stop using the building for manufacturing after I claim the deduction?
What’s the difference between this and the immediate expensing for manufacturing equipment?
What happens to the deduction if my building isn’t ready until 2030 or later?
Planning to build, buy, or expand a manufacturing facility?
A short conversation now can save a costly mistake later. ClearWealth helps Ontario manufacturers assess eligibility, time decisions, and file elections correctly. You can also explore our services.
Book a ConsultationSources & References
- → Department of Finance Canada — Consultation on draft legislative proposals (Jan 29, 2026): https://www.canada.ca/en/department-finance/programs/consultations/2026/consultation-on-draft-legislative-proposals-to-implement-certain-tax-measures-announced-in-budget-2025-or-earlier.html
- → Department of Finance Canada — News release (Jan 29, 2026): https://www.canada.ca/en/department-finance/news/2026/01/government-launches-consultation-on-draft-legislation-for-previously-announced-and-technical-tax-measures.html
- → Parliamentary Budget Officer — LEG-2526-012-S: https://www.pbo-dpb.ca/en/publications/LEG-2526-012-S–accelerated-capital-cost-allowance-immediate-expensing-measures–mesures-deduction-amortissement-accelere-passation-charges-immediate
- → Canada Revenue Agency — What’s new for corporations: https://www.canada.ca/en/revenue-agency/services/tax/businesses/topics/corporations/whats-new-corporations.html
- → PwC Canada — Tax Insights: Bill C-15: https://www.pwc.com/ca/en/services/tax/publications/tax-insights/bill-c-15-implements-changes-2025.html
