Life Choice – Tax Court of Canada finds that there can be no SR&ED without testing

A naturopathic products company (Life Choice) reviewed the literature and consulted other researchers in order to devise three new naturopathic formulations. In finding that this did not qualify as SR&ED, Boyle J stated that “it is the absolute absence of testing of the natural health products by Life Choice after their formulations were hypothesized by Dr. Dahl that is fatal to this appeal.”

Neal Armstrong Summary of Life Choice Ltd. v. The Queen, 2017 TCC 21 under s. 248(1) – scientific research & experimental development.