A Canco with excess credits could use them to offset the imputed interest on a PLOI to its NR parent

A Canadian high tech company with operating losses and no immediate use for SR & ED credits could get more benefit from them by making a loan to its non-resident parent which is elected under s. 15(2.11) to be a PLOI and then use such credits to offset the imputed interest on the PLOI.

Neal Armstrong. Summary of Bal Katlai, “Simple Planning Around Outbound Loans Using Tax Incentives,” Canadian Tax Highlights, Vol. 27, No. 12, December 2019, p. 9 under s. 15(2.11).