New Ontario Made Manufacturing Investment Tax Credit
The Ontario government is proposing a new Ontario Made Manufacturing Investment Tax Credit (“OMTC”). The OMTC will be a 10 per cent refundable corporate income tax credit available to Canadian-controlled private corporations (“CCPC”) that have a permanent establishment in Ontario that make eligible capital investments in buildings, machinery and equipment used in manufacturing or processing in Ontario.
The OMTC would be available for eligible capital costs incurred up to a limit of $20 million in a taxation year, resulting in a maximum annual credit available of up to $2 million. The OMTC will be a refundable tax credit, meaning it will be available to eligible CCPCs irrespective of whether the CCPC has taxes payable in the applicable taxation year.
The $20 million limit would be shared amongst an associated group of corporations and would be prorated for a short taxation year.
Eligible investments would be expenditures for certain capital property included in Class 1 or Class 53 for capital cost allowance (CCA) purposes:
- Class 1: Eligible expenditures would include capital costs for constructing, renovating, or acquiring buildings used for manufacturing or processing in Ontario that become available for use* on or after March 23, 2023. To qualify as a building used for manufacturing, 90 per cent of the floor space of the building must be used at the end of the corporation’s taxation year for manufacturing or processing in Ontario and the building must be eligible for the additional six per cent CCA permitted under the Federal Income Tax Act.
- Class 53: Eligible expenditures would include capital costs for machinery and equipment used in the manufacturing or processing of goods in Ontario. The machinery and equipment would have to be acquired and become available for use* on or after March 23, 2023, and before 2026. After 2025, eligible capital costs would include expenditures for machinery and equipment used in the manufacturing or processing of goods for sale or lease that are included in Class 43(a).
*“Available for use” refers to the rules set out in the Federal Income Tax Act that define the taxation year in which a taxpayer can start to claim CCA for a depreciable property.