The appellants, Biscuiterie Dominic Inc. and La Petite Bretonne Inc., appealed the Minister's refusal to recognize six food development projects as scientific research and experimental development (SR&ED) activities for the 2017 and 2018 taxation years.
The projects involved modifying recipes to improve shelf life and replace ingredients.
The Tax Court of Canada dismissed the appeals, finding that the appellants failed to demonstrate that the projects involved technological risk or uncertainty that could not be removed by routine engineering or standard procedures.
