Jentel Manufacturing Ltd. v. Canada, 2012 DTC 5031 [at at 6682], 2011 FCA 355 -- summary under Scientific Research & Experimental Development

By services, 28 November, 2015

The taxpayer, a producer of plastic containers, undertook a project to "improve the existing product to make it a smaller and significantly lighter storage system" (para. 9 of Statement of Appeal, quoted at para. 5). The Court agreed with the trial judge that the taxpayer's methods, which included changing the type and thickness of plastic used, changing the moulds and the casting materials, and using different types of material for the stand, did not entail "technological risk or uncertainty which could not be removed by routine engineering or procedures" (para. 6).

The taxpayer's argument that there was "no process in existence that could create moulded plastic items with the shapes, features and capabilities sought" was not persuasive. Evans J.A. stated (at para. 10):

Jentel acknowledges that a major part of the manufacturing technology puzzle was pre-existing. ... This recognition that thermoforming and injection moulding techniques and procedures were pre-existing (and therefore accessible to other professionals in the field), coupled with the fact that Jentel had previously used both methods and did not suddenly begin to use them in the 2005 fiscal year, supports the reasonableness of the judge's conclusion that Jentel was using an available, standard manufacturing process.

The taxpayer's SR&ED credits were therefore denied.

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