Words and Phrases - "equipment"

a
85
b
44
c
76
d
50
e
38
f
31
g
18
h
14
i
73
j
2
k
2
l
32
m
55
n
25
o
38
p
79
q
3
r
76
s
89
t
46
u
15
v
9
w
22
y
2

Inflection Analytics Ltd. v. The Queen, 2015 DTC 1126 [at at 786], 2015 TCC 129 (Informal Procedure)

Summary Under
Tax Topics - Income Tax Act - Section 37 - Subsection 37(8) - Paragraph 37(8)(a) - Subparagraph 37(8)(a)(ii) - Clause 37(8)(a)(ii)(A)
data licence was not equipment lease

The taxpayer, a developer of market analysis software, paid fees to purchase or license historical securities data in order to simulate market conditions in testing. Boyle J agreed with the Minister that this agreement could not be considered a licence of "equipment" for the purpose of the taxpayer's claims for SR&ED credits. The taxpayer merely had the right to access information via a website rather than "any rights in equipment of the vendor that can be used by the Appellant as it wishes, as was the case [with a US mainframe and a dedicated line to access it] in Datakinetics." (Para. 10.)

Words and Phrases
equipment