30 July 2004 External T.I. 2004-0083841E5 F - Développement informatique -- summary under A

Before noting that the treatment of a computer system development project could only be addressed in response to a ruling request, CRA stated:

In determining whether a taxpayer has acquired software or an interest in software … it is necessary to determine whether there has been such an acquisition under civil law or under common law, depending on which legal regime applies to the transaction.