A CCPC is a private corporation resident in Canada that is not controlled, directly or indirectly, by non-residents or public corporations.
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| Category | Corporate tax |
|---|---|
| Also known as | Canadian-controlled private corporation |
| Test | Private, Canadian-resident, and not controlled by non-residents or public corporations |
| Tested | Continuously; status can be lost mid-year on a share transfer |
| Rides on it | Small business deduction, refundable investment tax mechanics, capital gains exemption on qualifying shares |
| Authority | Canada Revenue Agency |
CCPC status unlocks most of the tax advantages of incorporating in Canada: the small business deduction, an extra month to pay corporate tax, enhanced R&D credits, and the lifetime capital gains exemption on a sale of qualifying shares. Control is tested on both a legal and a factual basis, so a shareholders' agreement, an option, or a financing arrangement that gives a non-resident effective control can cost CCPC status even where the share register looks fine. Status is tested continuously, not once at incorporation — bringing on a non-resident investor can end it mid-year.
Control is measured both legally, by votes, and in fact — a shareholders' agreement, a funding arrangement or an option that gives a non-resident or public corporation effective control will break CCPC status even where the share register looks Canadian. This matters most on a financing round. Taking investment from a foreign parent or a public company can cost the small business deduction and the capital gains exemption on the shares, and the loss is not always obvious until the return is prepared. Status is also tested throughout the year, not just at year end. A mid-year share transfer creates a deemed year end in some cases and splits the annual limits between the two periods.
A definition only gets you so far. Talk to a Montréal CPA about what this means for your return — in English or French.