Subsection 125.1(3) - Definitions
Canadian Manufacturing and Processing Profits
Cases
Canada v. Irving Oil Ltd., 2002 DTC 6716, 2001 FCA 364
The taxpayer, who carried on an active business of refining crude oil and marketing refined petroleum products, paid the amount of a disputed...
Allarcom Pay Television Limited v. The Queen, 98 DTC 6646 (FCA)
The taxpayer, which was a licensed pay television company that purchased rights to movies, and retaped them with introductions and commentary onto...
Publi-Hebdos Inc. v. Her Majesty the Queen, [1995] 2 CTC 330, 95 DTC 5547
The taxpayer, which published and distributed free of charge two newspapers 75% of whose space was devoted to advertising, was characterized as...
The Queen v. International Petrodata, Inc., 95 DTC 5335, [1995] 2 CTC 13 (FCA)
The taxpayer, which gathered, edited and interpreted technical data for wells drilled for oil and gas, and placed that data on computer tapes or...
The Queen v. Lehmann Bookbinding Ltd., 95 DTC 5063, [1995] 2 CTC 129 (FCTD)
The taxpayer, whose commercial book-binding business entailed the binding of issues or volumes of periodicals, the binding of monographs and the...
The Queen v. Veritas Seismic (1987) Ltd., 94 DTC 6123 (FCA)
The taxpayer, which used computer programs to process data from a few tapes in order to create images of sections of the surface of the earth...
Harvey C. Smith Drugs Ltd. v. The Queen, 95 DTC 5026 (FCA)
In finding that the taxpayer was not eligible for the manufacturing and processing deduction, Desjardins J. stated (p. 5030):
"By its very...
Stowe-Woodward Inc. v. The Queen, 92 DTC 6149, [1992] 1 CTC 209 (FCTD)
The taxpayer, which received roll cores from pulp and paper companies, and then prepared a rubber material which it applied in a continuous...
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| Tax Topics - General Concepts - Evidence | 41 |
Rolls-Royce (Canada) Ltd. v. The Queen, 91 DTC 5579, [1991] 2 CTC 252 (FCTD), aff'd 93 (DTC) 5031 (FCA)
The taxpayer's customers' engines were removed from aircraft, overhauled by the taxpayer and then reintroduced into the same customers' aircraft....
Tenneco Canada Inc. v. The Queen, 91 DTC 5207 (FCA)
In finding that a corporation which assembled and installed exhaust systems in automobiles was not engaged in manufacturing ("producing for sale...
Reg Rad Tech Ltd. v. The Queen, 90 DTC 6350, [1990] 2 CTC 77 (FCTD), aff'd 91 D.T.C 5518 (FCA)
The taxpayer purchased raw film, took x-rays or ultrasound films of patients referred to it by a partnership of radiologists (five of the original...
The Queen v. Nowsco Well Service Ltd., 90 DTC 6312, [1990] 1 CTC 416 (FCA)
The taxpayer provided various services to oil and gas operators respecting the completion and stimulation of wells including pumping cement...
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| Tax Topics - Statutory Interpretation - Resolving Ambiguity | 32 |
Dixie X-Ray Associates Ltd. v. The Queen, 88 DTC 6076, [1988] 1 CTC 69 (FCTD)
The taxpayer processed and developed x-ray films of patients who had been referred to radiologists who were its shareholders. The patients were...
Canadian Marconi v. R., 86 DTC 6526, [1986] 2 CTC 465, [1986] 2 S.C.R. 522
Interest, which an electronic equipment manufacturer received from short term loans and certificates of deposit which it had acquired out of the...
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Active Business | 13 | |
| Tax Topics - Statutory Interpretation - Resolving Ambiguity | 50 |
Halliburton Services Ltd. v. The Queen, 85 DTC 5336, [1985] 2 CTC 52 (FCTD), aff'd 90 DTC 6320 (FCA).
The appellant, which pumped custom-made cement, fracturing fluids and acid blends (the "goods") into the oil and gas wells of its customers, was...
Crown Tire Sevice Ltd. v. The Queen, 83 DTC 5426, [1983] CTC 412 (FCTD)
The taxpayer, in retreading worn tires before returning the tires to its customers, was providing a service to its customers rather than...
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| Tax Topics - Income Tax Act - Section 125.1 - Subsection 125.1(3) - Manufacturing or Processing (l) | 16 | |
| Tax Topics - Statutory Interpretation - Provincial Law | 83 |
Levi Strauss of Canada, Inc. v. The Queen, 82 DTC 6070, [1982] CTC 65 (FCA)
The modus operandi of the taxpayer corporation was to contract out all of the cutting, making and trimming of shirts. This function thus was not a...
Canadian Clyde Tube Forgings Ltd. v. The Queen, 82 DTC 6041, [1982] CTC 21 (FCA)
Machining operations in the taxpayer's plant were always carried out by a subcontractor rather than the taxpayer's employees. Payments to the...
McGraw-Hill Ryerson Ltd. v. The Queen, 80 DTC 6211, [1980] CTC 280, aff'd 82 DTC 6142, [1982] CTC 167 (FCA)
A textbook publisher was held to be engaged in the manufacturing or processing of books. Although the typesetting, printing and binding of the...
Modern Miss Sportswear Ltd. v. The Queen, 80 DTC 6390, [1980] CTC 521 (FCTD)
The payment by a garment manufacturer of the invoices of contractors to which it had farmed out the sewing of its garments could not be treated as...
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Salary or Wages | 45 |
MDS Health Group Ltd. v. The Queen, 79 DTC 5279, [1979] CTC 337 (FCTD)
Medical laboratories were not engaged in the processing of goods for sale. The analysis of specimens by the laboratories did not result in an end...
Canadian Wirevision Ltd. v. The Queen, 79 DTC 5101, [1979] CTC 122 (FCA)
A cable television company argued unsuccessfully that it was processing goods for resale when it processed T.V. signals for transmission to its...
See Also
Centre de traitement de la biomasse de la Montérégie inc. v. Agence du revenu du Québec, 2021 QCCA 1068
A processor of organic sludge was paid by suppliers in the agri-food industry for taking over the sludge, which it then treated and transformed,...
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| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Consideration | consideration for a transfer of waste included the assumption of environmental responsibility | 455 |
C.R.I. Environnement Inc. c. La Reine, 2008 DTC 3787, 2007 TCC 206, aff'd 2008 DTC 2471, 2008 FCA 103
The taxpayer, who in consideration for a charge made by it to its customers, sorted, consolidated and reshipped industrial waste produced by them,...
TDS Group Limited v. The Queen, 2005 DTC 786, 2005 TCC 40
The taxpayer, which sprayed automobile and truck parts with a corrosion inhibitor and specially packed them in kits before shipping the kits to...
Irving Oil Ltd. v. The Queen, 2000 DTC 2164 (TCC)
In finding that refund interest received by the taxpayer following a successful appeal of a substantial assessment represented business income...
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| Tax Topics - Income Tax Regulations - Regulation 5202 - Adjusted Business Income | 105 |
Cintas Canada Ltd. v. R., 99 DTC 926, [1999] 3 CTC 2036 (TCC)
The taxpayer carried on a uniform rental business under which it agreed to lease uniforms to customers for a period generally of five years and,...
Will-Care Paving & Contracting Ltd. v. The Queen, 97 DTC 506, [1996] 2 CTC 2426 (TCC)
The production of asphalt for use in the paving of driveways, parking lots and small public roadways was found not to qualify as use for contracts...
Mont-Sutton Inc. v. The Queen, 96 DTC 1472, [1996] 3 CTC 2492 (TCC)
The making of artificial snow by a ski resort operator ("Sutton") did not qualify as manufacturing or processing of goods for sale or lease. "As...
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| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 29 | 12 |
Démolition A.M. de l'est du Québec Inc. v. MNR, 93 DTC 889, [1993] 2 CTC 2447 (TCC)
The taxpayer, which derived its revenues from contracts for the demolition of buildings or other works, and from the sale of materials resulting...
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| Tax Topics - Income Tax Act - Section 125.1 - Subsection 125.1(3) - Manufacturing or Processing - Paragraph (c) | 22 | |
| Tax Topics - Statutory Interpretation - Provincial Law | 82 | |
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 29 | containers used for sorting materials essential to their processing | 274 |
Hope Brook Gold Inc. v. Minister of Finance of Newfoundland (1992), 96 DLR (4th) 114 (Nfld. C.A.)
In finding that electric trucks used by a gold mine to transport crushed ore to the surface, and carbon regeneration kilns used to restore carbon...
International Petrodata Inc. v. The Queen, 93 DTC 110, [1993] 1 CTC 2189 (TCC)
The sale and leasing of tapes and microfiches containing technical data on Canadian oil wells which the taxpayer had gathered, edited and...
Tuyauteries Saglac Inc. v. MNR, 93 DTC 40, [1992] 2 CTC 2727 (TCC)
In finding that an operation of installing industrial pipes and fittings in paper mills to the detailed and intricate specifications of the owners...
Versa Services Ltd. v. MNR, 92 DTC 1769, [1992] 2 CTC 2119 (TCC)
Microwave ovens and coffee brewers used by customers of the taxpayer's coin-operated vending machines in order to heat such products as hotdogs,...
Industrial Forest Reserves Ltd. v. MNR, 92 DTC 1060 (TCC)
The taxpayer's subsidiary carried out an aerial triangulation process in order to produce and provide a map framework to the taxpayer. The...
Design One Creative Graphic Productions Ltd. v. MNR, 92 DTC 1006, [1991] 2 CTC 2667 (TCC)
The taxpayer was found to be engaged in manufacturing when it prepared final art boards out of clear sheets of acetate and sold the boards to its...
Calgary Television Ltd. v. MNR, 90 DTC 1577, [1990] 2 CTC 2036 (TCC)
Fees charged by a television station to advertisers as for air time during the live telecast of hockey games and other presentations was not...
Fiat Auto Canada Ltd. v. The Queen, 83 DTC 5451, [1983] CTC 432 (FCTD)
It was stated in the context of the Excise Tax Act that the addition of radios by a Canadian distributor to imported motor vehicles "would not, in...
Royal Bank of Canada v. Deputy Minister of National Revenue for Customs and Excise, 81 DTC 5301, [1982] CTC 183, [1981] 2 S.C.R. 139
The taxpayer was a bank which also was the landlord of the Royal Bank Centre in Toronto. In that capacity, it operated emergency electricity...
Controlled Foods Corp. Ltd. v. The Queen, [1980] CTC 491, 80 DTC 6373 (FCA)
The preparation of meals and beverages by a restaurant did not constitute "manufacturing or producing" in the generally accepted commercial view...
The Queen v. York Marble, Tile and Terrazzo Ltd., [1968] S.C.R. 140, [1968] CTC 44, 68 DTC 5001
The respondent imported “greyish, non-descript” slabs of raw marble (sometimes as long as 16 feet) and, after finishing them, installed them...
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| Tax Topics - Statutory Interpretation - Similar Statutes/ in pari materia | Customs Tariff legislation was in pari materia to the Excise Tax Act | 411 |
Biltrite Tire Co. v. The King, [1937] S.C.R. 364, 1 D.T.C. 360
The taxpayer purchased in bulk lots, by the pound, old and worn-out motor vehicle tires and put them through a process of repair, treatment...
Administrative Policy
7 March 2019 Internal T.I. 2018-0781511I7 F - Fabrication ou transformation
9406917 F, after referencing the position in IT-145R, para. 42 that various activities of a printing firm constituted manufacturing or processing,...
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| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 29 | printing or photocopying operations may no longer be manufacturing or processing | 169 |
S4-F15-C1 - Manufacturing and Processing
Meaning of "manufacturing" and "processing".
1.2 ... [T]he manufacture of goods normally involves the creation of something (for example, making...
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| Tax Topics - Income Tax Act - Section 125.1 - Subsection 125.1(3) - Canadian Manufacturing and Processing Profits |
25 March 2013 External T.I. 2012-0470501E5 - Manufacturing and processing
CRA indicated that "it might be reasonable to consider that the production, packaging and sale of ice cubes and blocks could be processing or...
22 January 2009 External T.I. 2008-0290971E5 F - Bénéfices de fabrication et de transformation
An operation of the taxpayer consists of taking products, received in bulk in boxes, and dividing them up by category according to specific...
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| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 29 | equipment used in dividing and repackaging bulk goods was not “processing” equipment | 164 |
19 December 2008 External T.I. 2008-0299321E5 F - Exploitation forestière et DBFT
Corporation B, in managing a lumberyard owned by Corporation A, grades and cuts logs and arranges for the sale or chipping of the log residues. ...
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| Tax Topics - Income Tax Regulations - Regulation 5202 - Cost of Manufacturing and Processing Labour | fees of another corp. for managing the taxpayer’s log processing operation could qualify as "cost of manufacturing and processing labour" | 97 |
11 February 2002 Internal T.I. 2001-0102747 F - FABRICATION ET TRANSFORMATION
The construction contracts had more than a merely incidental services component so that they were not for the sale of product.
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| Tax Topics - Income Tax Act - Section 125.1 - Subsection 125.1(3) - Manufacturing or Processing - Paragraph (c) | M&P activity not assimilated to construction business where half the gross revenues were from sales | 80 |
| Tax Topics - Income Tax Act - Section 9 - Timing | contract completion method can be used by a non-construction business company | 48 |
26 March 2001 External T.I. 2001-0073495 - MANUFACTURING & PROCESSING
After noting that the "processing of goods usually refers to a technique of preparation, handling or other activity designed to effect a physical...
6 February 2001 External T.I. 2000-0059485 F - DBFT - Sous-traitants - textile
Regarding a taxpayer who carries on a business of designing and distributing clothing in Canada but who has its products manufactured by a third...
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| Tax Topics - Income Tax Regulations - Regulation 5202 - Qualified Activities | no cost of labour or qualifying activities if the core manufacturing activities are outside Canada | 284 |
21 March 1996 Internal T.I. 9605927 - INTEREST ON OVERPAYMENT AND ADJUSTED BUSINESS INCOME
Interest arising under s. 164(3) due to a refund of an overpayment resulting from a court-ordered reassessment, should be viewed as interest...
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| Tax Topics - Income Tax Regulations - Regulation 402 - Subsection 402(3) | 24 |
8 March 1993 T.I. (Tax Window, No. 29, p. 4, ¶2446)
In determining whether the manufacturing and processing deduction is available to the producer of a television show, the important consideration...
2 March 1993 T.I. (Tax Window, no. 29, p.18, ¶2450)
Embalming and cosmetic surgery performed on cadavers is not eligible for the manufacturing and processing deduction.
91 C.R. - Q.33
The judgments in the Nowsco Well and Haliburton Services cases are applicable only for taxpayers in the oil or gas well service industry with...
25 July 1991 T.I. (Tax Window, No. 7, p. 18, ¶1373)
A funeral home which normally contracts out the manufacture of caskets to third parties is not the manufacturer of the caskets for purposes of s....
18 January 1991 T.I. (Tax Window, Prelim. No. 3, p. 26, ¶1097)
Discussion of the M&P activities of the meat, bakery and produce departments of a grocery store.
88 CPTJ - Q.10
The treatment of sour gas by a gas plant is considered to be processing because there would normally be by-products that would be derived from...
79 C.R. - Q.21
The mixing of the ingredients for a drink by a barman, and the combination of ingredients by a vending machine to make coffee, drinks and soup,...
IT-145R "Canadian Manufacturing and Processing Profits - Reduced Rate of Corporate Tax".
Manufacturing or Processing
Administrative Policy
S4-F15-C1 - Manufacturing and Processing
Meaning of "manufacturing" and "processing".
1.2 ... [T]he manufacture of goods normally involves the creation of something (for example, making...
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| Tax Topics - Income Tax Act - Section 125.1 - Subsection 125.1(3) - Canadian Manufacturing and Processing Profits |
15 January 2015 External T.I. 2014-0548101E5 F - Sens de "fabrication ou transformation"
A steel plating company manufactured an alloy of various metals using specialized machinery, which was then applied to steel rods to make them...
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| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 29 | “primarily” based on the fraction of time used in the qualifying activities | 110 |
Paragraph (a)
Cases
Serres Toundra Inc. v. Agence du revenu du Québec, 2023 QCCQ 10441
The Quebec manufacturing and processing credits claimed by Serres Toundra in connection with equipment acquired for use by it in its greenhouse...
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| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Farming | a greenhouse operation is farming, not manufacturing or processing | 184 |
See Also
Ferme Lunick Inc. v. Agence du revenu du Québec, 2020 QCCQ 1703
The taxpayer operated a 1500-acre farm with four employees that produced potatoes, grains, market garden and dairy products, as well as a...
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| Tax Topics - Income Tax Act - Section 4 - Subsection 4(1) - Paragraph 4(1)(a) | a farm with a substantial potato-bagging operation carried on a single farming business | 195 |
Administrative Policy
S4-F15-C1 - Manufacturing and Processing
Separate processing operations of fishing corporation
1.11 ... [W]here substantial processing activities are carried out on board a vessel in...
Paragraph (b)
Administrative Policy
S4-F15-C1 - Manufacturing and Processing
End of logging
1.12 ... [L]ogging does not include activities that take place after the delivery of the logs to a sawmill, pulp mill, plywood...
Paragraph (c)
Cases
Nova Construction Co. Ltd. v. The Queen, 85 DTC 5594, [1986] 1 CTC 68 (FCA)
A company engaged in highway construction used a "blackmobile" to produce asphaltic concrete at the site of a sand and gravel pit by passing sand...
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| Tax Topics - Income Tax Regulations - Regulation 1104 - Subsection 1104(9) - Paragraph 1104(9)(c) | 34 |
See Also
Démolition A.M. de l'est du Québec Inc. v. MNR, 93 DTC 889, [1993] 2 CTC 2447 (TCC)
Garon J. rejected the Crown's submission that the activities of the taxpayer in demolishing buildings and other works constituted "construction".
| Locations of other summaries | Wordcount | |
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| Tax Topics - Income Tax Act - Section 125.1 - Subsection 125.1(3) - Canadian Manufacturing and Processing Profits | 64 | |
| Tax Topics - Statutory Interpretation - Provincial Law | 82 | |
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 29 | containers used for sorting materials essential to their processing | 274 |
Chateau Manufacturing Ltd. v. Dep. MNR, 84 DTC 6126, [1984] CTC 43 (FCA)
Construction materials are not limited to goods which are intended to be assembled on a construction site, but also can include goods which are...
Administrative Policy
14 February 2014 External T.I. 2013-0504601E5 F - Bénéfices de fabrication et de transformation
Company A, whose business was to construct roads, produced asphalt and sold over 90% of its production in constructing roads. A related...
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| Tax Topics - General Concepts - Separate Existence | avoidance through M&P carried on through related corp | 33 |
17 June 2002 Internal T.I. 2001-0111717 F - BFT ET CONSTRUCTION MAISON EN USINE
In finding that a fabricator of manufactured homes was engaged in a manufacturing and processing given that the exclusion for “construction”...
11 February 2002 Internal T.I. 2001-0102747 F - FABRICATION ET TRANSFORMATION
After noting its position that a “manufacturing or processing activity is considered to form an integral part of the construction undertaking if...
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| Tax Topics - Income Tax Act - Section 125.1 - Subsection 125.1(3) - Canadian Manufacturing and Processing Profits | not sale of products where services component of construction contract was not incidental | 23 |
| Tax Topics - Income Tax Act - Section 9 - Timing | contract completion method can be used by a non-construction business company | 48 |
Paragraph (d)
Administrative Policy
S4-F15-C1 - Manufacturing and Processing
Straddle plant excluded
1.14 The processing of natural gas at a straddle plant in Canada and the processing of natural gas in a plant in Canada...
Paragraph (e)
See Also
Continental Lime Ltd. v. R, 99 DTC 1154, [1999] 3 CTC 2525 (TCC)
The processing activities of the taxpayer in producing lime were held to include the transport of limestone from one of its quarries to its...
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| Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees | defence protected income stream | 145 |
Paragraph (f)
Subparagraph (f)(i)
Administrative Policy
24 May 2005 External T.I. 2005-0121291E5 F - Processing in Canada of ore
Mineco crushes nickel ore underground in its mine. Opco, which operates a bulk ore hauling business in Canada, uses a mobile crushing plant (the...
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|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 1204 - Subsection 1204(1) - Paragraph 1204(1)(b) - Subparagraph 1204(1)(b)(iii) - Clause Subparagraph 1204(1)(b)(iii)(A) | second crushing of nickel ore at the surface generated gross resource profits | 142 |
| Tax Topics - Income Tax Regulations - Schedules - Schedule II - Class 10 - Paragraph 10(k) | mobile plant of subcontractor used at mine surface level to further crush ore before its transport qualified under 10(k) | 106 |
Paragraph (h)
Administrative Policy
S4-F15-C1 - Manufacturing and Processing
Electricity for own use not excluded
1.17 The production or processing of electrical energy or steam used directly or indirectly by taxpayers in...
Paragraph (i)
See Also
Nova Construction Sand and Gravel Ltd. v. The Queen, 80 DTC 6298, [1980] CTC 378 (FCA)
The fact that the word "producing" in s. 125.1(3)(b) appears to be used in contradistinction to the word "processing", the references in other...
Manufacturing or Processing (l)
Cases
Range Grain Co. v. R., 97 DTC 5221, [1997] 2 CTC 227 (FCTD)
The processes of cleaning, fumigating and ventilating grain in a transfer elevator of the taxpayer did not qualify as processing because those...
Qit-Fer et Titane Inc. v. The Queen, 92 DTC 6071, [1992] 1 CTC 39 (FCTD), aff'd on different grounds 96 DTC 6213 (FCA)
Rouleau J. applied s. 15(1) of the Interpretation Act in finding that because ss.125.1(3)(b)(v), (vi) and (vi.1) excluded the production of ferric...
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|---|---|---|
| Tax Topics - Statutory Interpretation - Interpretation Act - Subsection 15(1) | 107 | |
| Tax Topics - Statutory Interpretation - Interpretation Act - Subsection 33(3) | 105 | |
| Tax Topics - Statutory Interpretation - Interpretation/Definition Provisions | presumption against redundancy | 63 |
Crown Tire Sevice Ltd. v. The Queen, 83 DTC 5426, [1983] CTC 412 (FCTD)
The onus is upon the taxpayer to establish that the 10% test has been satisfied.
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| Tax Topics - Income Tax Act - Section 125.1 - Subsection 125.1(3) - Canadian Manufacturing and Processing Profits | service of retreading tires | 43 |
| Tax Topics - Statutory Interpretation - Provincial Law | 83 |
See Also
Le Soleil Limitée v. MNR, 73 DTC 5093, [1973] CTC 91 (FCA)
The "gross revenues ... from sales" of a newspaper included its advertising revenues.