Hélène Robitaille
Senior Manager | CPA, CA, LL.M. Fisc. | Tax

Further to the March 26, 2015 budget, Bill 112, adopted February 8, 2017, implements the Finance Minister’s intention to extend the obligation to produce a disclosure form for tax credits that exceed $25,000.

This disclosure must be made if one of the following conditions is met:

  • Remuneration is conditional (this is the condition most likely to apply);
  • Taxpayers sign a confidentiality agreement;
  • Taxpayers receive contractual protection.

Deadline for filing the disclosure

In the case of refundable tax credits, the deadline is the same as the one granted to submit the prescribed form. For corporations, this corresponds to 18 months after year end. In other cases, when the transaction is realized after this deadline, it is extended to the transaction realization date.

Revenu Québec grants a 60-day period, up to April 9, to file missing returns. As for refundable credits, it’s not necessary to file a disclosure for fiscal years ended before January 1, 2014.


The penalty is $10,000 plus $1,000 per day, as of the second day, up to a maximum of $100,000. Furthermore, the prescription period has been extended. At the symposium, La RS & DE et autres mesures incitatives à l’innovation, presented on February 23 and 24, 2017 by the Association de planification fiscale et financière, Revenu Québec specified that the penalty would not be automatic. However, given the amounts in question, better safe than sorry!

27 Mar 2017  |  Written by :

Ms. Robitaille is a senior manager at RCGT. She is your expert in taxation for the Montreal office....

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