Budget 2021: Corporate tax measures

April 19, 2021 BDO CANADA

The Federal Budget proposes the following tax changes for businesses.

Immediate expensing of depreciable property

The Budget proposes to allow Canadian Controlled Private Corporations (CCPCs) to immediately expense eligible acquisitions for tax purposes up to a maximum amount of $1.5 million per taxation year. This change will apply for eligible depreciable property acquired on or after April 19, 2021 and that becomes available for use prior to 2024. The $1.5 million limit must be shared among associated members of a group of CCPCs and will be prorated for short taxation years. Eligible property for this measure will not include assets with longer depreciation periods that is property in CCA Classes 1 to 6, 14.1, 17, 47, 49, and 51, which includes buildings, structures, goodwill, parking lots, and pipelines. This measure should provide assistancefor CCPCs to make capital investments to grow their businesses.

Tax rate reduction for zero-emission technology manufacturers

The Budget proposes to temporarily reduce corporate income tax rates for qualifying companies involved in zero-emission technology manufacturing or processing activities. The new corporate tax rate will be 7.5% where that income would otherwise be taxed at the 15% general corporate tax rate, and 4.5% where that income would otherwise be taxed at the 9% small business tax rate. The reduced tax rates will apply to taxation years that begin after 2021 and will gradually start to be phased out in taxation years that begin in 2029 and be fully phased out for taxation years that begin after 2031.

Taxpayers that have income subject to both the general and small business tax rates will be able to choose to have their eligible income taxed at either of the reduced rates of 4.5% or 7.5%. The amount of income taxed at 4.5% plus the amount of income taxed at the small business rate of 9% cannot exceed the business limit.

Capital cost allowance (CCA) for clean energy equipment

The Budget proposes to expand the assets included in CCA Classes 43.1 and 43.2 that allow for accelerated tax deductions to support investment in clean technologies. This proposal is applicable to qualifying property that is acquired and becomes available for use on or after April 19, 2021.

Film or video production tax credits

The Budget proposes to temporarily extend certain timelines for both the Canadian Film or Video Production Tax Credit and the Film or Video Production Services Tax Credit. This is in recognition of the disruptions to film and video productions caused by the COVID-19 pandemic.

Mandatory disclosure rules

The government announced it will consult on proposals to enhance Canada's mandatory disclosure rules. In addition to new requirements to report notifiable transactions, certain larger taxpayers will need to disclose uncertain tax positions.

Avoidance of tax debts

Canadian tax law has an anti-avoidance rule designed to prevent taxpayers from avoiding their tax liabilities by transferring assets to non-arm's length persons for insufficient consideration. To address tax planning designed to avoid these rules, the Budget proposes a number of measures that will apply to transfers undertaken on or after April 19, 2021.

For more information, please contact:

Dave Walsh, Managing Partner, Tax Service Line

Rachel Gervais, Partner, GTA Tax Service Line Leader

Greg London, Partner, Eastern Canada Tax Service Leader

Bruce Sprague, Partner, Western Canada Tax Service Leader


The information in this publication is current as of April 19, 2021.

This publication has been carefully prepared, but it has been written in general terms and should be seen as broad guidance only. The publication cannot be relied upon to cover specific situations and you should not act, or refrain from acting, upon the information contained therein without obtaining specific professional advice. Please contact BDO Canada LLP to discuss these matters in the context of your particular circumstances. BDO Canada LLP, its partners, employees and agents do not accept or assume any liability or duty of care for any loss arising from any action taken or not taken by anyone in reliance on the information in this publication or for any decision based on it.

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