Ministère des Finances
Ministère des Finances
Ministère des Finances
In brief, the eligibility conditions for the new tax holiday for large investment projects are as follows:
Only a corporation or partnership may apply for an initial qualification certificate.
A group of corporations and/or partnerships cannot file an application for joint eligibility, whether through a joint venture or otherwise.
The application for an initial qualification certificate must be submitted before any significant expenditures for the completion of the investment project have been incurred.
Significant expenditures for the completion of the investment project have been incurred if the total amount of capital expenditures incurred in respect of the investment project exceeds $1 million at the time of the application for the initial qualification certificate.
This rule applies to expenses incurred. Some of them may therefore not have been paid out at the time the application is submitted.
The application for an initial qualification certificate must be submitted to the Minister of Finance no later than December 31, 2029.
The minimum threshold for investment expenditures relating to the large investment project is $100 million.
The total investment expenditures attributable to the completion of the investment project includes all the capital expenditures incurred, during the investment period applicable to the investment project for the acquisition of new property required for the carrying out of the investment project.
The minimum threshold of investment expenditures must be reached before the expiry of the 48-month investment period.
A corporation or partnership may choose the date on which the 48-month investment period applicable to its investment project begins. This date must be within 12 months of the filing of the application for the initial qualification certificate.
This date must be chosen when the application for the initial qualification certificate is submitted.
This rule applies to expenses incurred. Some of them may therefore not have been paid out by the end of the 48-month investment period.
The activities arising from the large investment project must be carried out in Québec.
In addition, the property must be used mainly in Québec and in the course of activities arising from the carrying out of the large investment project.
The same investment project may be carried out in more than one region. In this case, the proportion of eligible expenditures incurred in each region will determine the region in which the investment project is considered to be carried out.
The large investment project must not be carried out in an excluded sector of activity.The list of excluded sectors of activity can be found on page A.21 of Additional Information – March 2023.
Will also be deemed excluded activities that are reasonably attributable to the hosting, production or sharing of content :
In addition, to claim the tax holiday for a particular year, the corporation or partnership must not be excluded, that is, the proportion of its gross income that comes from activities carried out in an excluded sector of activity must not exceed 25% of its total gross income. Revenu Québec will administer this rule and verify its application once the corporation has completed its investment project.
A project whose activities relate to code NAICS 21 is considered to be a project concerning critical and strategic minerals (CSM) when the project is mainly attributable to CSM.
Please note: “mainly” generally means 50% or more, and “all or substantially all” generally means 90% or more.