After finding that the Quebec investment tax credit under the Taxation Act (“TA”) reduces the cost of depreciable property under s. 13(7.1) rather than being required to be included in income under s. 12(1)(x), CRA addressed the timing of the deduction, stating:
[A] taxpayer is entitled to receive government assistance in the form of a deduction from tax or in any other form of assistance where the taxpayer has a definite right to receive such assistance even though the amount of the assistance may not necessarily be payable. …
[T]he corporation is entitled to receive this credit for the purposes of paragraph 13(7.1)(f) when the conditions of the first paragraph of section 1029.8.36.166.43 of the TA are satisfied, that is, at the end of the taxation year in which it claims the credit. However, it is not entitled to receive the portion of the credit that is carried forward to a subsequent taxation year. Furthermore, the corporation is not considered to have received this credit until it has submitted the prescribed documents and information, it is shown that the corporation is entitled to the credit and it is applied as a payment of tax due by the corporation or at the time the credit is actually paid.