What is the likelihood of
changing a CRA reviewer’s mind after they have made a proposal about your
claim? I have seen such a change occur….more
than once…..but such a result is a minority outcome.
This is unfortunate because I am
increasingly finding that to CRA, SRED is whatever the RTA reviewing the claim
says it is. Reviewers have a knack for sending lengthy documented refusals that
are very short on technological information and reflect no relevant hands-on
experience with the technology that is the context of the claim. Too often I am
seeing reviews done by people that display no evidence of technical proficiency
in the activities for which the reviewed claim has been made. At once time I thought that such experiences
were isolated, but I have become jaded, and I am forming the impression that
perhaps there is an agency wide strategy within CRA to reduce claims and wear
out claimants, albeit politely.
This is not to imply that your
review will be done by incompetents. There are some very bright reviewers, and
some really helpful ones, but the fact that appeals to SRED related assessments
are now several times what they were a few years ago should say something about
what is happening. The data at this link
is informative: https://www.scitax.com/pdf/Bulletin.55.Statistics.Reveal.Dramatic.Increase.in.SR&ED.Appeals.11-Apr-2014.pdf.
