2 December 2015 Internal T.I. 2015-0621231I7 - Insulin pens

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.

Principal Issues: Whether the cost of an insulin pen would be eligible for the medical expense tax credit

Position: Likely yes

Reasons: The pen would be considered a syringe or needle designed to be used for the purpose of giving an injection

December 2, 2015

Canada Revenue Agency HEADQUARTERS
Legislative Policy Directorate Income Tax Rulings
22th Floor, Place de Ville, Tower A Directorate
Ottawa, ON, K1A 0L5 Eric Wirag, CPA, CMA
Attention: Janet Schermann (613) 670-9053

2015-062123
Insulin Pens

We are replying to your email of December 2, 2015, in which you asked whether an insulin pen would be an eligible expense for the medical expense tax credit.

It is our understanding that when an individual is required to take insulin, there are three methods to choose from: (i) a syringe, (ii) an insulin pen, or (iii) an insulin pump. It is the insulin pen that you are enquiring about.

We understand that there are two types of insulin pens:

• A reusable pen – This type of pen houses an insulin cartridge within the pen itself, with each cartridge containing multiple insulin dosages. Once the cartridge is emptied a new cartridge is replaced within the same pen. The pen requires a new needle for each dosage administered.
• A disposable pen – This pen contains the insulin within the pen and the whole pen is disposed of once the insulin has been emptied. These pens also have multiple dosages within each pen, and a new needle is needed for each dose.

Paragraph 5700(b) of the Income Tax Regulations specifies that a “needle or syringe designed to be used for the purpose of giving an injection” is a device or equipment prescribed for the purposes of paragraph 118.2(2)(m) of the Income Tax Act. It is our view that both the reusable insulin pen and the disposable insulin pen would meet the requirements of paragraph 5700(b) of the Regulations.

Unless exempted, a copy of this memorandum will be severed using the Access to Information Act criteria and placed in the Canada Revenue Agency’s electronic library. After a 90-day waiting period, a severed copy will also be distributed to the commercial tax publishers for inclusion in their databases. You may request an extension of this 90-day period. The severing process removes all content that is not subject to disclosure, including information that could reveal the identity of the taxpayer. The taxpayer may ask for a version that has been severed using the Privacy Act criteria, which does not remove taxpayer identity. You can request this by e-mailing us at: ITRACCESSG@cra-arc.gc.ca. A copy will be sent to you for delivery to the taxpayer.

If you have any questions regarding the above, please do not hesitate to contact us.

Pamela Burnley, CPA, CA
Manager, Tax Credits and Ministerial Issues
Business and Employment Division
Income Tax Rulings Directorate