2025 Federal Budget analysis: Investing in Canada’s future

In brief

On November 4, 2025, the Minister of Finance and National Revenue, François-Philippe Champagne, presented the government’s budget. The budget:

• provides temporary immediate expensing for the cost of acquiring, or making additions or alterations to, eligible buildings used for manufacturing & processing
• confirms changes to the scientific research and experimental development tax incentive program previously announced in the 2024 Fall Economic Statement and further increases the expenditure limit on which enhanced credits can be earned
• expands the list of critical minerals eligible for existing tax credits and extends the availability of full tax credit rates for carbon capture utilization and storage expenditures
• introduces a limit on the potential deferral of tax on investment income through the use of tiered corporate structures in certain situations
• modifies Canada’s transfer pricing rules
• eliminates the Underused Housing Tax and the luxury tax on aircrafts and vessels
• confirms the government’s intention to proceed with many outstanding tax measures announced by the previous government

This Tax Insights discusses these and other tax initiatives proposed in the budget.

In detail

Business tax measures

Immediate expensing for manufacturing and processing buildings

The capital cost allowance (CCA) system determines the deductions that a business may claim each year for income tax purposes in respect of the capital cost of its depreciable property. Depreciable property is generally divided into CCA classes with each having its own rate in the Income Tax Regulations. These rates generally align with the expected useful life of the assets in their classes.

Currently, eligible buildings in Canada used to manufacture or process goods for sale or lease (manufacturing or processing buildings) are prescribed a CCA rate of 10%. This includes the regular CCA rate of 4% under Class 1, plus an additional allowance of 6% for manufacturing or processing buildings. To be eligible for the 6% additional allowance, at least 90% of the building’s floor space must be used to manufacture or process goods for sale or lease.

The budget proposes to provide temporary immediate expensing for the cost of eligible manufacturing or processing buildings, including the cost of eligible additions or alterations made to such buildings. The enhanced allowance would provide a 100% deduction in the first taxation year that eligible property is used for manufacturing or processing, provided the minimum 90% floor space requirement is met.

Property that has been used, or acquired for use, for any purpose before it is acquired by the taxpayer would be eligible for immediate expensing only if both of the following conditions are met:

• neither the taxpayer nor a non-arm’s-length person previously owned the property, and
• the property has not been transferred to the taxpayer on a tax-deferred “rollover” basis

In cases where a taxpayer benefits from immediate expensing of a manufacturing or processing building, and the use of the building is subsequently changed, recapture rules may apply.

This measure would be effective for eligible property that is acquired on or after November 4, 2025 and is first used for manufacturing or processing before 2030. An enhanced first-year CCA rate of 75% would be provided for eligible property that is first used for manufacturing or processing in 2030 or 2031, and a rate of 55% would be provided for eligible property that is first used for manufacturing or processing in 2032 or 2033. The enhanced rate would not be available for property that is first used for manufacturing or processing after 2033.

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Scientific research and experimental development (SR&ED)

The budget proposes to, effective for taxation years beginning after December 15, 2024, increase the annual SR&ED expenditure limit, under which certain corporations are entitled to earn an enhanced 35% refundable investment tax credit (ITC), to $6 million. This is in addition to the 2024 federal Fall Economic Statement (FES) proposals that significantly enhance the SR&ED program by expanding SR&ED ITC refundability and restoring eligibility for capital expenditures (for more information on the 2024 FES SR&ED proposals, see our Tax Insights “SR&ED updates: Enhanced credits, expanded eligibility and emerging opportunities”).

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Critical Mineral Exploration Tax Credit

Flow-through shares allow corporations to renounce or "flow through" Canadian exploration expenses (CEE), including Canadian renewable and conservation expenses (CRCE), and Canadian development expenses (CDE) to investors, who can deduct the expenses in calculating their own taxable income (at a 100% rate for CEE, including for CRCE, and at a 30% rate on a declining-balance basis for CDE).

The Critical Mineral Exploration Tax Credit (CMETC) provides an additional income tax benefit for individuals who invest in eligible flow-through shares. The CMETC is equal to 30% of specified mineral exploration expenses incurred in Canada and renounced to flow-through share investors. The following critical minerals are currently eligible for the CMETC: nickel, cobalt, graphite, copper, rare earth elements, vanadium, tellurium, gallium, scandium, titanium, magnesium, zinc, platinum group metals, uranium and lithium (including lithium from brines).

The budget proposes to expand the eligibility of the CMETC to include the following additional critical minerals: bismuth, cesium, chromium, fluorspar, germanium, indium, manganese, molybdenum, niobium, tantalum, tin and tungsten.

This measure would apply to expenditures renounced under eligible flow-through share agreements entered into after November 4, 2025 and on or before March 31, 2027.

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Clean Technology Manufacturing ITC

The Clean Technology Manufacturing ITC is a refundable tax credit equal to 30% of the cost of investments in new machinery and equipment used to manufacture or process key clean technologies, or to extract, process, or recycle critical minerals essential for clean technology supply chains (i.e. lithium, cobalt, nickel, graphite, copper and rare earth elements).

The budget proposes to expand the list of critical minerals eligible for the Clean Technology Manufacturing ITC to include antimony, indium, gallium, germanium and scandium.

This measure would apply in respect of property that is acquired and becomes available for use on or after November 4, 2025.

The budget also confirms that the government will move forward with the 2024 budget proposal of the previous government to expand eligibility for the Clean Technology Manufacturing ITC for certain polymetallic projects.

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ITC for Carbon Capture, Utilization, and Storage (CCUS)

The CCUS ITC is a refundable tax credit that provides support for eligible expenditures relating to CCUS.

The CCUS ITC provides three different credit rates depending on the purpose of the equipment, with the following credit rates applying to eligible CCUS expenditures incurred from the start of 2022 to the end of 2030:

• 60% for eligible capture equipment used in a direct air capture project
• 50% for all other eligible capture equipment, and
• 37.5% for eligible transportation, storage and use equipment

Eligible expenditures that are incurred from the start of 2031 to the end of 2040 are subject to the lower credit rates set out below:

• 30% for eligible capture equipment used in a direct air capture project
• 25% for all other eligible capture equipment, and
• 18.75% for eligible transportation, storage and use equipment

The extent to which the CCUS ITC is available to a CCUS project and respective eligible equipment depends on the end use of the carbon dioxide (CO₂) being captured. Eligible uses include dedicated geological storage and storage in concrete, but not enhanced oil recovery.

Extension of full tax credit rates

The budget proposes to extend the availability of the full credit rates by five years, so that the full rates apply to eligible expenditures incurred from the start of 2022 to the end of 2035. Eligible expenditures that are incurred from the start of 2036 to the end of 2040 would continue to be subject to the lower credit rates described above.

The government will also postpone by five years the review of the CCUS ITC rates that was announced in the 2022 budget. Under this new timeline, the review will be undertaken before 2035 (rather than before 2030).

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Clean Electricity ITC and Canada Growth Fund

The Clean Electricity ITC is a refundable credit equal to 15% of the capital cost of eligible investments in equipment related to low-emitting electricity generation, electricity storage, and the transmission of electricity between provinces and territories.

This tax credit would be available to taxable Canadian corporations, provincial and territorial Crown corporations, corporations owned by municipalities or Indigenous communities, pension investment corporations and the Canada Infrastructure Bank. The capital cost of property that is eligible for the Clean Electricity ITC may be reduced by government assistance that a taxpayer receives.

The budget proposes to:

• include the Canada Growth Fund as an eligible entity under the Clean Electricity ITC
• introduce an exception so that financing provided by the Canada Growth Fund would not reduce the cost of eligible property for the purpose of computing the Clean Electricity ITC

These measures would apply to eligible property that is acquired and that becomes available for use on or after November 4, 2025.

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Tax deferral through tiered corporate structures

The Income Tax Act (ITA) includes a set of rules that seek to prevent the use of Canadian-controlled private corporations (CCPCs) to defer personal income tax on investment income. Investment income earned by a CCPC is subject to an additional refundable tax that increases the corporation’s tax rate to approximate the highest marginal combined federal-provincial personal income tax rate. A corporation is entitled to a refund of a portion of this additional tax when it pays a taxable dividend. The refund reflects the fact that a shareholder who is an individual is subject to personal income tax on a taxable dividend.

Unlike an individual shareholder, a corporate shareholder is generally not subject to income tax on a taxable dividend received from another corporation because it can claim an offsetting inter-corporate dividend deduction. However, additional anti-deferral rules in Part IV of the ITA may impose a special refundable tax on the recipient corporation when it receives the taxable dividend. In particular, if the recipient corporation receives a taxable dividend from a “connected corporation” (generally, a corporation that owns shares carrying more than 10% of the votes and value of the payer corporation), a refundable tax is levied on the recipient corporation corresponding to the amount of the payer corporation’s dividend refund.

Part IV tax is payable by the recipient corporation on the balance-due day for its taxation year in which the dividend is received. This day can be after the balance-due day for the payer corporation’s taxation year in which the dividend was paid (e.g. if the corporations have different taxation year ends). Certain tax planning techniques have been employed to take advantage of this timing difference to defer, at times indefinitely, the tax liability on investment income by interposing corporations with staggered year ends in a corporate chain. For example, a corporation may pay a taxable dividend at a time that is in the payer corporation’s 2025 taxation year and in the recipient corporation’s 2026 taxation year, in order to defer the tax liability on the investment income of the corporate group to the recipient’s balance-due day for its 2026 taxation year (rather than being payable on the payer corporation’s balance-due day for 2025).

The budget proposes to limit the deferral of tax on investment income using tiered corporate structures with mismatched year ends. In general terms, the proposed limitation would suspend the dividend refund that could be claimed by a payer corporation on the payment of a taxable dividend to an affiliated recipient corporation if the recipient corporation’s balance-due day for the taxation year in which the dividend was received ends after the payer corporation’s balance-due day for the taxation year in which the dividend was paid. The determination of whether the dividend payer and payee are affiliated would be based on current affiliation rules in the ITA.

This rule would not apply if each corporate dividend recipient in the chain of affiliated corporations pays a subsequent dividend on or before the payer’s balance-due day, such that no deferral is achieved by the affiliated corporate group. To accommodate bona fide commercial transactions, the rule would also not apply to a dividend payer that is subject to an acquisition of control where it pays a dividend within 30 days before the acquisition of control.

The payer corporation would generally be entitled to claim the suspended dividend refund in a subsequent taxation year when the recipient corporation pays a taxable dividend to a non-affiliated corporation or an individual shareholder.

This measure would apply to taxation years that begin on or after November 4, 2025.

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Eligible activities under the Canadian exploration expense

Canadian exploration expenses (CEE) may include expenses incurred by a taxpayer for the purpose of determining the existence, location, extent or quality of a mineral resource in Canada.

CEE is a category of tax deduction that can be transferred from mining corporations via flow-through shares to equity investors, who can then claim a 100% immediate deduction on account of CEE. Further, individuals (other than trusts) who invest in these flow-through shares may be able to claim the Mineral Exploration Tax Credit or the CMETC in respect of certain types of CEE.

The determination of a mineral resource’s “quality” for CEE purposes has historically been interpreted by the CRA to relate to the resource’s underlying physical characteristics. Expenses for technical studies (which are typically undertaken to assess a mineral resource’s engineering feasibility and economic viability as a mining project, rather than its underlying physical characteristics) have generally been viewed by the CRA as being excluded from CEE.

A recent decision of the Supreme Court of British Columbia held that the reference to “quality” under the provincial equivalent of the federal CEE definition could be interpreted to include the economic viability, and not just the physical characteristics, of a mineral resource.

The budget proposes to amend the ITA to clarify that expenses incurred for the purpose of determining the quality of a mineral resource in Canada do not include expenses related to determining the economic viability or engineering feasibility of the mineral resource.

This amendment would apply as of November 4, 2025.

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Agricultural cooperatives: patronage dividends paid in shares

Before 2005, patronage dividends paid in shares by an agricultural cooperative to its members were taxable to the members in the year the shares were received. The cooperative paying the dividend was also required to withhold an amount from the dividend and remit it to the CRA on account of the recipient’s tax liability.

In 2005, the tax rules were amended to allow for the temporary deferral of income taxes and withholding obligations on patronage dividends received as eligible shares until the disposition (including a deemed disposition) of the shares. An eligible share must not, except in the case of death, disability or ceasing to be a member, be redeemable or retractable within five years of its issue. The current measure is set to expire at the end of 2025.

The budget proposes to extend this measure to apply in respect of eligible shares issued before the end of 2030.

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International tax measures

Transfer pricing

The transfer pricing rules are generally relevant for transactions (or series of transactions) between a Canadian taxpayer and non-resident persons with whom the taxpayer does not deal at arm’s length.

• If the terms or conditions of such a transaction (or series) differ from those that would be made or imposed between persons dealing at arm’s length, any amounts in respect of the transactions (or series) may be adjusted for purposes of the ITA, to reflect arm’s length terms and conditions.
• If the relevant transaction (or series) would not have been entered into by arm’s length persons (and cannot reasonably be considered to have been entered into primarily for bona fide non-tax purposes), any amounts in respect of the transaction (or series) may be adjusted to reflect the transactions that would have been entered into between arm’s length persons.

The budget proposes significant changes to the transfer pricing rules; these changes are somewhat similar to certain changes proposed in a consultation paper released by the Department of Finance on June 6, 2023 (for information on the consultation paper, see our Tax Insights “Finance launches consultation on reforming and modernizing Canada's transfer pricing rules”). The proposed changes are intended to modernize Canada’s transfer pricing rules and better align these rules with the international consensus on the application of the arm’s length principle. 

The budget proposes the following key changes:

• The transfer pricing rules would generally be applied so as to achieve consistency with the Organisation for Economic Co-Operation and Development’s Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (the OECD Guidelines). The proposed rule references the version of the OECD Guidelines published in 2022, as well as any other text that may be published in the Income Tax Regulations.
• When applying the transfer pricing rules, a relevant transaction (or series) would be analyzed and determined with reference to its economically relevant characteristics. These characteristics are defined in the legislation, and include the contractual terms, the functions performed by the parties, the characteristics of the relevant properties or services, the economic and market context, and the business strategies of the parties. The proposed rule aims to delineate the relevant transactions based on the actual conduct of the parties, not just the legal terms.
• The transfer pricing analysis would compare the actual conditions between the participants in the transaction (or series) to the conditions that would have applied between arm’s length persons in comparable circumstances (including the possibility that arm’s length persons would have entered into different transactions, or no transactions). “Conditions” are defined broadly and include any commercial or financial information relevant to the transaction (or series). A transaction (or series) would be deemed to have actual conditions different from arm’s length conditions if it lacks certain conditions that would have been included had the parties been dealing with one another at arm's length in comparable circumstances.
• Where the actual conditions of a transaction (or series) differ from arm’s length conditions, any amounts relevant for the ITA may be adjusted to reflect the arm’s length conditions. This would replace the existing transfer pricing adjustment rules described above. The budget notes that this adjustment rule would allow a relevant transaction (or series) to be replaced with an alternative transaction (or no transaction at all), but consistent with the OECD Guidelines, this would be done only in exceptional circumstances.

The budget also proposes certain changes to certain administrative aspects of the transfer pricing rules:

• the de minimis threshold for the transfer pricing penalty would be increased from $5 million to $10 million
• the transfer pricing documentation requirements would be modified to provide clarity and better align with the new transfer pricing rules
• simplified documentation requirements would be available where prescribed conditions are met (these conditions are not included in the budget), and
•  the time limit for taxpayers to respond to a request for documentation from the CRA would be reduced from three months to 30 days

This measure would apply to taxation years beginning after November 4, 2025.

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Investment income derived from assets supporting Canadian insurance risks

Certain income earned by a controlled foreign affiliate of a Canadian taxpayer is treated as foreign accrual property income (FAPI), which is included in the taxpayer’s income on an accrual basis. A specific rule treats a foreign affiliate’s income from the insurance of Canadian risks as FAPI (with an exception for certain affiliates that earn more than 90% of their gross premium revenue from non-Canadian risks of arm’s length persons). In this context, Canadian risks refers to risks in respect of Canadian-resident persons, businesses carried on in Canada, or property situated in Canada.

The budget proposes to amend this rule to expand its scope. Under the amended rule, a foreign affiliate’s income from the insurance of Canadian risks would include income from holding any property by the affiliate in connection with the insurance of Canadian risks by any person or partnership. This means that income from investments that are held to support Canadian insurance risks will be treated as FAPI, even if the risks are insured by a different entity.

This measure would apply to taxation years of foreign affiliates that begin after November 4, 2025.

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Personal tax measures

Lowest personal tax rate and top-up tax credit

The budget reminds us that the government has committed to reducing the lowest marginal personal income tax rate from 15% to 14.5% for 2025 and then to 14% for 2026. However, this also reduces the value of many existing personal tax credits for all taxpayers, as these credits are calculated using the lowest tax bracket rate. As a result, when an individual’s non-refundable tax credit amounts exceed the first income tax bracket threshold ($57,375 in 2025), the decrease in the value of these credits may exceed their tax savings from the rate reduction.

To ensure that these individuals do not have their tax liability increased by the lowest marginal tax rate cut, the budget proposes to introduce the non-refundable Top-Up Tax Credit, effective for the 2025 to 2030 taxation years. The credit will effectively maintain the current 15% rate for non-refundable tax credits claimed on amounts that exceed the first income tax bracket threshold.

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Canadian Entrepreneurs’ Incentive

The budget cancels the Canadian Entrepreneurs' Incentive that was announced in the 2024 budget. That measure would have allowed certain individuals to reduce their capital gains inclusion rate on dispositions of certain small business corporation shares.

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Personal Support Workers Tax Credit

The budget introduces a temporary refundable tax credit for eligible personal support workers working for eligible health care establishments, equal to 5% of eligible earnings up to a maximum of $1,100 per year, effective for the 2026 to 2030 taxation years. Eligible health care establishments are hospitals, nursing care and residential care facilities, community care facilities for the elderly, home health care establishments and other similar regulated health care establishments.

This credit will be available in provinces and territories that are not covered by a bilateral agreement with the federal government to increase wages for personal support workers. Only British Columbia, Newfoundland and Labrador and the Northwest Territories are signatories to this bilateral agreement.

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Qualified investments for registered plans

The budget proposes to simplify and harmonize the qualified investment rules for the purposes of registered plans through several measures.

First, the budget would enable Registered Disability Savings Plans (RDSPs) to acquire shares of small business corporations, venture capital corporations and specified cooperative corporations. However, shares of eligible corporations, interests in small business investment limited partnerships and small business investment limited trusts would no longer be qualified investments. Interests in small business investment limited partnerships and small business investment trusts that were acquired before 2027 would be grandfathered, and shares of eligible corporations would remain qualified under the rules. These changes would apply as of January 1, 2027.

Second, the budget proposes to replace the registered investment regime with two new categories of investments that do not require registration:

• units of trusts subject to National Instrument 81-102
• units of investment funds managed by a registered investment fund manager under National Instrument 31-103

The new qualified investment rules apply effective November 4, 2025, and the registered investment regime would be repealed effective January 1, 2027.

Third, the budget would simplify the qualified investment rules for six types of registered plans into one definition.

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Home Accessibility Tax Credit

The budget would prevent the same expense from being claimed under both the Home Accessibility Tax Credit and the Medical Expense Tax Credit, aligning the rules to avoid double benefits. This change would apply for the 2026 and later taxation years, while existing credit parameters remain unchanged.

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21-year rule

The ITA contains an anti-avoidance rule that prevents a trust from deferring the deemed disposition of its assets on its 21^st anniversary. 

The budget proposes to broaden the anti-avoidance rules to include situations where property is transferred indirectly from one trust to another in order to circumvent the 21-year deemed disposition of trust assets. This measure will apply to transfers that occur after November 3, 2025.

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Automatic federal benefits for lower-income individuals

The budget proposes to amend the ITA to grant the CRA the discretionary authority to file a tax return for a taxation year on behalf of a lower-income individual, among other criteria. The CRA would, before filing a return on behalf of an eligible individual, provide the individual with the information it has available at the time, and the eligible individual would have 90 days to review the information and submit changes to the CRA. If the eligible individual does not confirm the information (with or without changes) by the end of the 90 days, the CRA could file a tax return on the individual’s behalf, and then issue a notice of assessment, and subsequently determine and issue the individual’s credit and benefit entitlements. This measure is proposed to apply to the 2025 and subsequent taxation years (i.e. filing could begin in 2026).

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Indirect tax measures

Elimination of Underused Housing Tax

The budget proposes to eliminate the Underused Housing Tax (UHT) as of the 2025 calendar year. No UHT would be payable and no UHT returns would be required to be filed in respect of the 2025 and subsequent calendar years.

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Luxury tax on aircraft and vessels

Effective November 5, 2025, the budget eliminates the luxury tax on sales, importations, leases and certain improvements of aircraft and vessels. Registered vendors of these items should file final luxury tax returns for reporting periods that include November 4, 2025. Their luxury tax registrations will be cancelled effective February 1, 2028, at which point vendors will no longer be able to claim rebates. Luxury tax will continue to apply on sales of vehicles.

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Carousel fraud

The budget proposes a “reverse charge mechanism” (RCM) to combat so-called “carousel schemes” in the telecommunications sector. A carousel scheme involves a network of businesses that create a circular supply chain of goods or services, with each member claiming input tax credits on goods and services tax/harmonized sales tax (GST/HST) paid to the previous supplier. One entity, known as a “missing trader,” collects GST/HST, but disappears before remitting the tax to the government.

The RCM would apply to supplies of certain telecommunications services, such as voice-over-internet protocol minutes. Where the RCM applies, rather than the supplier collecting and remitting GST/HST on a supply, the recipient would be required to self-assess and report the GST/HST payable and, if registered for GST/HST at the time of the supply, would be entitled to claim an input tax credit.

Supplies of other goods or services may be subjected to the RCM by regulation in the future.

A consultation is open in respect of the proposed rules until January 12, 2026.

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Previously announced measures

The budget confirms that the government has considered each of the outstanding tax measures announced by the previous government and confirms that it intends to proceed with most (but not all) of the measures, as modified to take into account consultations and deliberations since their release, including (note that the following is not a comprehensive list):

• legislative and regulatory proposals released on August 15, 2025, including those relating to:
  • the capital gains rollover on small business investments
  • reporting by non-profit organizations,¹ subject to a deferred application date for taxation years beginning January 1, 2027 or later (the government is reviewing feedback it has received and will release final proposals in due course)
  • the SR&ED tax incentive program²
  • the Crypto-Asset Reporting Framework³ and the Common Reporting Standard⁴ (subject to a deferred application date of January 1, 2027)
  • the tax exemption for sales to Employee Ownership Trusts and to Worker Cooperatives
  • non-compliance with information requests⁵
  • the excessive interest and financing expenses limitation rules⁶
  • substantive CCPCs
  • technical tax amendments to the ITA and the Income Tax Regulations (subject to a deferred application date for reporting by bare trusts,⁷ so that it would apply to taxation years ending on or after December 31, 2026)
  • technical amendments to the Global Minimum Tax Act⁸
• legislative proposals released on January 23, 2025, to extend the 2024 charitable donations deadline
• legislative and regulatory proposals announced in the 2024 Fall Economic Statement,⁹ including those relating to:
  • expanding eligibility under the Clean Electricity ITC to the Canada Infrastructure Bank
  • modifying the Small Nuclear Energy Eligibility under the Clean Technology ITC
  • expanding eligibility under the Clean Hydrogen ITC to methane pyrolysis
  • extending the Accelerated Investment Incentive and immediate expensing measures
• legislative and regulatory proposals released on August 12, 2024, including those relating to:
  • alternative minimum tax (other than changes related to resource expense deductions)
  • charities and qualified donees
  • Registered Education Savings Plans
  • avoidance of tax debts, mutual fund corporations, synthetic equity arrangements, and manipulation of bankrupt status
  • accelerated CCA for productivity-enhancing assets, and for purpose-built rental housing
  • withholding for non-resident service providers
  • regulations related to the application of the Enhanced (100%) GST Rental Rebate to cooperative housing corporations
  • Clean Electricity ITC, and expanding eligibility under the Clean Technology ITC to support generation of electricity and heat from waste biomass¹⁰
  • proposed expansion of eligibility for the Clean Technology Manufacturing ITC to support polymetallic extraction and processing¹⁰
  • amendments to the Global Minimum Tax Act and the Income Tax Conventions Interpretation Act¹¹
• the proposed increase in the lifetime capital gains exemption to apply to up to $1.25 million of eligible capital gains announced in the 2024 budget
• legislative amendments to implement the hybrid mismatch arrangements rules announced in 2021 budget

The budget also reaffirms the government’s commitment to move forward as required with technical amendments to improve the certainty of the tax system.

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