17 July 2018 External T.I. 2018-0747311E5 - Geothermal Energy Project -- summary under Class 14

After noting that different licence, lease and permit fees may be imposed under the applicable provincial law in connection with a geothermal project, CRA stated:

The fees paid for renewals and extensions of a licence could also be included in Class 14. Generally, where the renewals or extensions are automatic or within the control of the taxpayer, the overall term of the licence includes such additional periods. However, if there is a requirement for any further negotiations with, or the concurrence or consent of, the grantor of the licence, the new period would not be considered to be an automatic renewal but rather it could be a separate property eligible for inclusion in Class 14.

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