CRA states that whether aluminium shingles were a fixture turned on their purpose

New aluminum shingles with an electric cable (the “Equipment”) were attached over existing asphalt shingles on the portion of a roof immediately beneath existing solar panels, so as to melt snow accumulations, which otherwise would hinder the functioning of the solar panels. In order for the Equipment to qualify as Class 43.2 property, it could not be “part of the building,” i.e., it could not be a fixture.

CRA stated that this turned on the question of “whether an article is attached to another property to effect a permanent and substantial improvement of that other property or to enable [its] more complete enjoyment.” In then applying this test, it stated:

Here, the intention to install the Equipment is to resolve a problem caused by the deficient operation of the solar panels. Thus, the fact that the Equipment is necessary for the proper operation of the photovoltaic equipment during the winter period and that its main function is to support the solar panels (with any benefits to the building being negligible), may support the inclusion of its capital cost to Class 43.2… .

Neal Armstrong. Summary of 16 May 2017 External T.I. 2016-0670661E5 under Class 43.1.