Summary policy

Date
September 3, 2003 (Revised November 23, 2005)

Reference number
CSP-S16

Key words

Substantially all

Policy statement

The Canada Revenue Agency's position is that the expression "substantially all" used in the Income Tax Act means 90% or more.

References

• Summary policy CSP-R05, Business activity
• Income Tax Act, R.S.C. 1985 (5^th supp.) c. 1