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Comparaison entre le crédit pour R-D aux U.S vs au Canada

05 déc

Article de Yann Rousselot-Pailley dans la catégorie Etats-Unis, Financement, Gestion, International, R-D, canada, crédit d'impôt

Canada USA Research Development

Les aides gouvernementales canadiennes pour la R-D sont parmi les plus généreuses au monde, donnant ainsi un avantage compétitif significatif aux entreprises qui choisissent de réaliser leur RS&DE ici. De nombreuses études, prouvent qu’au Canada le coût de la R-D après impôt est le plus bas de toutes les nations du G7.

D’un autre côté, les États-Unis sont bien connus pour leurs entreprises innovantes. Des crédits d’impôt pour la R&D aux États-Unis sont également disponible pour stimuler entreprises innovantes déjà existantes et pour encourager la création de Startups.

Comparons donc les deux pays du point de vue du dirigeant d’une entreprise innovante.

U.S R-D tax credit

Over the past 25 years, the Research and Development Tax Credit has been an elusive target for many
businesses. Since its creation in 1981, the credit has died and been resurrected at least 11 times by
Congress but never made permanent.

Private industry expenditures for research and development have increased to about two-thirds of national
R&D spending, as the U.S government’s portion has declined, from 1.92 percent of GDP in 1964 to 0.80 percentof GDP in 2004, according to the Manufacturing Council. American manufacturers, who account for 14
percent of U.S. gross domestic product, claim about 60 percent of the credits.

While research and development is often considered the domain of large companies, smaller businesses
have more to gain, as the value of the R&D credit as a percentage of their assets can be as high as 9.4
percent. Of the 16,000 businesses using the R&D credit, more than 4,500 companies have assets of less
than $1 million.

The IRS (equivalent to CRA in Canada) defines R&D expenditures as those “incident to the development or improvement of a product,”including the costs and attorney’s fees associated with obtaining a patent. The IRS definition of “product” includes formulas, inventions, patent, pilot models, processes and techniques. Excluded expenditures include quality control testing, advertising and promotion, consumer surveys, efficiency surveys, management studies, research for literary, historical or similar projects, and the acquisition of another’s patent, model, production or process.
Businesses must determine their base amount of R&D expense based on the IRS criterias. The business can claim 20 percent of R&D expenses over that base amount, which will vary from business to business. The work must be done in the U.S. for U.S. research and development.

In 1996, Congress passed the Alternative Incremental Research Credit (AIRC), intended to help companies
with significant R&D expenditures who did not qualify for the credit due to economic circumstances during
the base period. The amount of the AIRC is typically less than the regular R&D credit. Businesses may be able to go back as far as three years in claiming the R&D credit.

Canada-U.S. Comparison of R&D Tax Credits
Canada	United States
Legislated ongoing tax credit program.	Legislated temporary tax credit program.
Qualified expenditures (SR&ED current and capital expenditures) are accumulated in an SR&ED expenditure pool. They can be 100% deducted in the current year or held in the pool to be deducted in any subsequent year. The SR&ED expenditure pool does not expire, and the timing and amount of deductions taken are at the discretion of the taxpayer.	Current R&D expenditures are 100% deductible in the year incurred, or may be amortized over a minimum period of 5 years.
SR&ED tax credits are calculated at 20% of qualified expenditures. For qualifying Canadian controlled private corporations, the tax credit rate is calculated at an enhanced rate of 35%, subject to an annual SR&ED expenditure limit of $3 million. In Quebec, an extra 37,5% of qualified expenditures is aplied for SBE, and 17,5% for large corporation. Quebec province, and the big city of Montreal, is one of the best place to do R-D in Canada	R&D credit is calculated as 20% of the excess of qualified research expenditures over a base amount, plus 20% of basic research payments.
After being applied to income taxes payable, the balance of credits to qualifying Canadian-controlled private corporations (i.e., those for whom the enhanced rate applies) are 100% refundable for current expenditures and 40% refundable for capital expenditures.	R&D credits are non-refundable.
Unused credits can be applied against taxes payable in the 3 preceding taxation years or the subsequent 20 taxation years.	Unused credits can be applied against taxes payable in the preceding taxation year or the subsequent 20 taxation years.
Total cost of arms length contracted R&D is eligible for tax credit.	65% of contracted R&D eligible for tax credit
Capital items are eligible for tax credit.	Capital items are not eligible for tax credit.
Work done by R-D’s employee is 100% eligible even if heshe spent 10% of the time outside Canada	Work must be done in U.S
Certain incremental overhead costs attributable to R&D activities are eligible for claim. A proxy method for calculating overhead, based on a percentage of R&D labour, is available as an alternative for ease of calculation.	Certain incremental overhead costs (e.g. utilities) may be eligible for claim.