If you have come to the world of SR&ED expecting that the CRA will treat you and your claims in a manner consistent with their published information, you will be sadly disappointed, and probably frustrated. It’s no wonder companies look to the assistance of consulting firms for help. It certainly doesn’t help matters when the definitions applied to words are being shifted, and loaded up with some unwelcome and extra freight in the form of additional meanings and implications that most of us just wouldn’t use.
I attended a CRA public information session recently, just to see what the current training session includes, and I noticed them applying a particular set of definitions and interpretations that could really spoil your day.
When we speak of technology, we usually refer to the set of tools, equipment, systems, networks, machinery, and so on, with which the business creates or delivers the goods, products or services on which the business is based. (Note that we are not speaking here about the goods, products or services themselves, but the technology set that underlies or enables them.)
To most people, talking about “technical uncertainty” would appear to mean the same thing as “technological uncertainty”. To the CRA, currently, these phrases carry materially different meanings. (I’m not sure if the rest of the world embraces these definitions and assumptions.) However, we need to equip ourselves for the discussion. Are the different definitions, discussed below, purely a clarification of old intentions? Do they represent a mostly academic debate about historically equivalent expressions? Or is this some kind of a semantic shell game designed to slash the definitions of eligible work, and organized around a nuance of language that CRA is alone in perpetuating?
To be continued…