Government of Canada Enacts Bill C-15
April 9, 2026
Sector:
Government of Canada Enacts Bill C-15: Sweeping Tax and Economic Reforms Now Law
On March 26, 2026, the Government of Canada granted Royal Assent to Bill C-15, officially titled “An Act to implement certain provisions of the budget tabled in Parliament on November 4, 2025.” This wide-ranging legislation enacts key measures from the 2025 federal budget and the 2024 Fall Economic Statement, marking one of the most significant tax overhauls in recent years.
Bill C-15 progressed quickly through Parliament: introduced on November 18, 2025, passed third reading on February 26, 2026, and received Senate approval without amendment.
A New Landscape for Business Taxation
Investment Incentives and Capital Cost Recovery
The bill reinstates accelerated Capital Cost Allowance (CCA) for most capital assets acquired after 2024 and available for use before 2030. These incentives will phase out starting in 2030 and end after 2033.
Immediate expensing has been extended to certain asset classes, and a new 10% CCA rate for purpose-built rental housing aims to boost residential development through 2036.
Clean Economy Investment Push
Bill C-15 advances Canada’s clean economy goals with several key measures:
- Launch of the Clean Electricity Investment Tax Credit (effective April 2024)
- Expanded eligibility for clean technology and manufacturing credits
- Extension of full carbon capture (CCUS) tax credit rates through 2035
- Broadening of eligible critical minerals
SR&ED: A Major Shift in Innovation Policy
One of the most impactful changes is the overhaul of the Scientific Research and Experimental Development (SR&ED) program:
- Refundable expenditure cap increased from $3 million to $6 million
- Eligibility expanded beyond traditional Canadian-controlled private corporations (CCPCs)
- Capital expenditures and lease costs reintroduced as eligible claims
These updates make SR&ED a powerful tool for scaling and capital-intensive companies. For example, a mid-sized robotics firm can now claim specialized testing equipment while benefiting from the higher refundable cap, improving cash flow for reinvestment.
Note: Larger claims will likely attract increased CRA scrutiny—strong documentation is essential.
Transfer Pricing and International Tax Reform
Canada’s transfer pricing rules have been modernized to better align with OECD standards, including:
- A single unified adjustment rule
- Enhanced documentation requirements
- Stricter penalty frameworks
Changes to Foreign Accrual Property Income (FAPI) rules also eliminate certain tax deferral opportunities for CCPCs earning passive income through foreign affiliates.
Additional Business Measures
- Lifetime Capital Gains Exemption (LCGE) increased to $1.25 million
- Mineral Exploration Tax Credit extended to 2027
- Expanded rollover provisions for qualifying share transfers
Personal Tax Changes: Targeted Relief and Incentives
Key personal tax measures include:
- $1.25 million lifetime capital gains exemption for individuals
- $10 million exemption for business sales to Employee Ownership Trusts
- Temporary top-up tax credit to offset lower marginal rates
- New refundable Personal Support Workers Tax Credit (2026–2030)
Updates also cover disability supports, housing accessibility credits, and the tax treatment of the Canada Disability Benefit.
Trusts and Estates: Reporting and Compliance Updates
- Bare trust reporting requirements deferred until 2026
- Expanded ability for estates to carry back capital losses
- Simplified filing for deceased individuals
- New exemptions and clarifications for certain trust structures
Indirect Tax Changes: Major Repeals
Several notable taxes have been rolled back:
- Digital Services Tax repealed retroactively to June 2024
- Underused Housing Tax eliminated for 2025 onward
- Luxury tax on aircraft and vessels removed as of November 2025
GST/HST rules have also been refined, including expanded rebates for student housing.
Enhanced Compliance and Administration
Bill C-15 strengthens tax administration through:
- Expanded CRA authority for withholding waivers for non-resident service providers
- New information-sharing with Employment and Social Development Canada to address worker misclassification
What This Means for Businesses and Individuals
Bill C-15 delivers a balanced mix of investment incentives, innovation support, and stronger compliance. Many measures are retroactive or include transitional rules. Businesses and individuals should review their tax positions promptly to take advantage of new opportunities.
Final Thoughts
From enhanced SR&ED incentives to the repeal of major indirect taxes, Bill C-15 fundamentally reshapes Canada’s tax system. Organizations focused on growth, innovation, or international operations now have substantial new tools — paired with higher expectations for compliance and documentation.
Need help assessing the impact on your business? Contact us today to consult with a qualified tax professional familiar with the latest CRA guidance: www.krestongta.com
Frequently Asked Questions about Bill C-15
When did Bill C-15 receive Royal Assent?
March 26, 2026.
What is the new SR&ED expenditure limit?
The refundable expenditure cap has doubled from $3 million to $6 million.
Has the Lifetime Capital Gains Exemption increased?
Yes — it is now $1.25 million for qualifying dispositions.


