

» Quick Answer
- Canada’s SR&ED expenditure limit for the enhanced 35% refundable investment tax credit doubled from $3 million to $6 million under Bill C-15, which received Royal Assent on March 26, 2026. The change applies to tax years beginning on or after December 16, 2024.
- A qualifying Canadian-controlled private corporation (CCPC) or eligible Canadian public corporation can now claim up to $2.1 million in refundable federal ITCs each year, up from the previous $1.05 million cap. The limit phases out linearly between $15 million and $75 million of prior-year taxable capital employed in Canada.
- Claims are filed on Form T661 with T2 Schedule 31 within 18 months of the corporation’s tax year-end. Ontario-based claimants may stack the 8% refundable Ontario Innovation Tax Credit on up to $3 million of qualified provincial expenditures.
» Why the Doubled SR&ED Limit Just Rewrote R&D Funding in Canada
Every founder running a Canadian R&D-heavy company just got roughly a million extra dollars of runway. That is the practical effect of the doubled Scientific Research and Experimental Development (SR&ED) expenditure limit, the biggest enhancement to Canada’s largest federal R&D incentive in over a decade.
Under the old rules, a qualifying Canadian-controlled private corporation could recover a maximum of $1.05 million per year in refundable federal credits. Under the new rules, that ceiling is $2.1 million. For a deep-tech startup burning through payroll, hardware, and contractor invoices, that difference can mean two extra quarters of runway without giving up a single share of equity.
Below is a plain-English guide to how the change works, who qualifies, how to file, and where the traps are. For a broader overview of the program, our earlier post on SR&ED tax incentives covers the fundamentals.
Maximum Federal Refundable SR&ED Credit: Before vs After Bill C-15
Enhanced 35% refundable ITC ceiling for a qualifying CCPC. Bill C-15 (Royal Assent March 26, 2026) doubled the expenditure limit from $3M to $6M.
» Quick Start: Pick Your Path
The right SR&ED path depends on your corporate structure, R&D spend, taxable capital, and province. Use the checklist below to jump to the section that matches your situation, then read the mechanics in full.
- →First-time claimant CCPC under $3 million in R&D spend: focus on the eligibility and filing sections. The doubled ceiling likely does not change your calculation yet, but the reinstated capital expenditure rules may.
- →Established CCPC spending between $3 million and $6 million on R&D: the doubled limit is the change that matters most for you. Read the mechanics section carefully.
- →Prior-year taxable capital between $15 million and $75 million: your enhanced limit is partially phased out. The phase-out chart shows exactly where you land.
- →Eligible Canadian public corporation: you are newly eligible for the refundable rate, a first for public companies.
- →Associated group filer: remember the $6 million ceiling is shared across all associated corporations, not one per company.
For hands-on help with any of these paths, our SR&ED and tax advisory services can walk you through it.
» Who Qualifies for the Enhanced 35% Refundable Rate
Three claimant categories exist under the enhanced SR&ED rules. Qualifying CCPCs and eligible Canadian public corporations can access the 35% refundable rate on up to $6 million of expenditures. All other corporations receive the 15% non-refundable rate instead.
The enhanced 35% refundable investment tax credit is the flagship of the SR&ED program because refundable means cash. The CRA pays it out even when the corporation has no tax owing, which is why founders describe it as non-dilutive funding.
A qualifying CCPC is a Canadian-controlled private corporation whose prior-year taxable capital employed in Canada sits below $75 million and whose prior-year taxable income sits below the applicable threshold. Both conditions matter. Miss either and the enhanced rate phases out.
An eligible Canadian public corporation is a new category introduced by Bill C-15. Eligibility hinges on a three-year average gross revenue test, so being publicly listed does not automatically qualify a corporation. Below the revenue threshold, the corporation accesses the same 35% refundable rate as a qualifying CCPC.
All other corporations, including large private companies, non-resident-controlled Canadian corporations, and CCPCs above the phase-out, receive the standard 15% non-refundable federal ITC. That credit reduces tax payable but does not generate a cash refund. Our guide to Canada’s corporate tax rates explains where each corporate category sits in the broader tax framework.
Federal ITC Rate and Refundability by Claimant Type
Not every corporation gets the enhanced 35% refundable rate. Refundable credits generate a cash refund; non-refundable credits only reduce tax owing.
» How the $6 Million Limit Actually Works
The $6 million enhanced expenditure limit applies to qualifying SR&ED spend in a tax year. The enhanced rate is 35%, so the maximum federal refundable credit is $2.1 million. The limit phases out between $15 million and $75 million of prior-year taxable capital.
The mechanics matter because a small change in taxable capital can shift the entire refund. Below $15 million in prior-year taxable capital employed in Canada, the full $6 million enhanced limit applies. Above $75 million, the enhanced limit is gone entirely and only the 15% non-refundable rate remains. Between those two points, the enhanced limit reduces on a straight line.
A worked example makes this concrete. A CCPC with $35 million in prior-year taxable capital sits roughly one-third of the way through the phase-out range. Its enhanced expenditure limit is approximately $4 million, so its maximum enhanced refundable ITC is around $1.4 million. Qualifying expenditures above that portion may still earn the 15% non-refundable federal ITC.
Two more mechanics matter. First, the $6 million limit is shared across associated corporations, so an associated group gets one ceiling, not one per company. Second, qualifying capital expenditures made after December 15, 2024 requalify for SR&ED after being ineligible for years. Manufacturers and hardware startups should revisit their eligible-cost calculations. For more, see our post on maximizing Canadian SR&ED opportunities.
Enhanced Expenditure Limit Phase-Out by Prior-Year Taxable Capital
The enhanced $6M SR&ED expenditure limit phases out linearly between $15M and $75M of prior-year taxable capital employed in Canada.
» Step-by-Step: Filing a SR&ED Claim Under the New Rules
SR&ED claims are filed on Form T661 and T2 Schedule 31, attached to the corporation’s T2 return, within 18 months of tax year-end. The process moves through five stages: confirm eligibility, document technical work, calculate eligible costs, file, and prepare for review.
- 1Confirm eligibilityNot all R&D qualifies. The CRA looks for scientific or technological uncertainty, systematic investigation, and technological advancement. If a project meets those three tests, its labour, materials, contractor, overhead, and (for expenditures after December 15, 2024) capital costs may qualify.
- 2Document technical work as you goA strong SR&ED file includes contemporaneous notes on the uncertainty faced, the hypotheses tested, the experiments run, and the results obtained. Waiting until year-end to reconstruct this record is the single biggest cause of denied claims.
- 3Calculate eligible costs by categorySalary and wages of employees directly engaged in SR&ED, materials consumed or transformed, and eligible contractor payments feed into the pool. Overhead can be included using either the traditional method or the prescribed proxy amount, which many smaller claimants find simpler to defend.
- 4File Form T661 with T2 Schedule 31Attached to the T2 corporate return, within 18 months of tax year-end. Missing that window is fatal because the CRA cannot accept a late SR&ED claim. Filing early is normal and recommended.
- 5Prepare for CRA reviewA meaningful share of SR&ED claims is selected for a technical or financial review each year, and being selected is not an accusation. Our insights library covers review preparation in more depth.
SR&ED Enhancement Timeline: Announcement to Enacted Law
From the Fall Economic Statement 2024 to Royal Assent of Bill C-15, showing the enhanced expenditure limit at each step.
» Stacking the Ontario Innovation Tax Credit With Federal SR&ED
For corporations with a permanent establishment in Ontario, the federal 35% refundable ITC is not the only cash on the table. The Ontario Innovation Tax Credit (OITC) is a refundable provincial credit worth 8% of qualified Ontario SR&ED expenditures, up to a $3 million annual expenditure limit.
The two credits stack. A qualifying Ontario CCPC spending $3 million on eligible SR&ED work performed in Ontario may claim both the 35% federal refundable ITC and the 8% Ontario refundable credit on the same qualified spend. On a $3 million eligible spend, the layered credits can approach $1.29 million in combined refunds.
Two conditions are essential. The corporation must have a permanent establishment in Ontario, and the SR&ED work must be performed in Ontario. Rules differ in Quebec, Alberta, and British Columbia. For a broader look at Ontario corporate compliance, see our guide to prorating Ontario corporate tax.
» Common Mistakes That Trigger a CRA SR&ED Review
Six mistakes account for most SR&ED review triggers. Each is preventable with basic discipline during the R&D year.
- →Weak project narratives that describe what was built rather than the technological uncertainty faced. The CRA needs to see the unknown, not the deliverable.
- →Missing contemporaneous evidence such as lab notebooks, code commit histories, test results, or engineering memos. Reconstructed documentation typically looks reconstructed.
- →Aggressive contractor time allocations, especially when contractors bill for a mix of SR&ED and non-SR&ED work but the claim assumes 100% eligibility. Split the time honestly.
- →Unsupported overhead assumptions when using the traditional method. If the proxy method is available, many claimants find it defensible and simpler.
- →Mishandled government assistance netting. Grants, forgivable loans, and other assistance reduce eligible expenditures, and failing to net them is a common error.
- →Late filings past the 18-month reporting deadline. Miss the window and the claim is lost, because the CRA has no discretion to extend it.
Structural choices also matter before you claim. Our guide to being self-employed or incorporated in Canada shows why SR&ED eligibility often makes incorporation the smarter route for R&D-focused businesses.
» Frequently Asked Questions
How much can my company actually get back under the new SR&ED $6 million limit?
When did the doubled SR&ED limit actually take effect?
Does my company qualify for the enhanced 35% refundable rate?
What happens if my prior-year taxable capital is between $15 million and $75 million?
Can I claim SR&ED for equipment and other capital purchases again?
What form do I file to claim SR&ED and when is it due?
How do the federal SR&ED credit and the Ontario Innovation Tax Credit work together?
What triggers a CRA review of a SR&ED claim?
Turn Your R&D Spend Into Cash
The doubled SR&ED expenditure limit is the most significant enhancement to Canada’s R&D tax framework in over a decade. If you are approaching a fiscal year-end or planning a claim, book a consultation with our team and we can help you file cleanly, stack Ontario credits where they apply, and prepare for CRA review.
Book a ConsultationSources & References
- Canada Revenue Agency — SR&ED news and updates. canada.ca/…/sred-updates
- Department of Finance Canada — Budget 2025 (November 4, 2025). canada.ca/…/federal-budget
- Parliament of Canada — Bill C-15, Budget 2025 Implementation Act, No. 1 (Royal Assent March 26, 2026). parl.ca/legisinfo
- Ontario Ministry of Finance — Ontario Innovation Tax Credit. ontario.ca/page/ontario-innovation-tax-credit
- CRA — Form T661 SR&ED Expenditures Claim. canada.ca/…/t661
- CRA — T2 Schedule 31 Investment Tax Credit. canada.ca/…/t2sch31
