Robotx Solutions – Tax Court of Canada finds that solving narrowly-cast production engineering problems was not SR&ED
There was something paradoxical about a company contractually committing itself to come up with narrowly defined solutions to particular production problems of its clients, e.g., designing, making and installing a “flow rectifier plate” to straighten-out rectangular aluminum bars coming out of an extruder, while at the same time treating a portion of its expenditures in performing such contracts as “experimental development,” which requires that there be significant technological uncertainty to be resolved, i.e., a significant chance that a solution would not be found within a predictable time frame.
Jorré J found that the company had not demonstrated that any of the work on four separate projects of this nature “was engaged in to resolve technological uncertainties that could not be resolved with current methods and existing knowledge.”
Neal Armstrong. Summary of Robotx Solutions Inc. v. The Queen, 2017 CCI 73 under s. 248(1) – scientific research & experimental development.