Productivity Mega Deduction: A New Tax Incentive for Investment in Canada

Eligible Property and Expenses

The Mega Deduction would allow businesses to deduct the full cost of many eligible investments in the first year, rather than spreading the deduction over several years. 

The measure would generally apply to depreciable property, including machinery, equipment, computers, data network infrastructure, certain zero-emission vehicles, patents and certain clean energy equipment. Immediate expensing would also be available in respect of Canadian development expenses incurred on or after September 15, 2026. 

Key Exclusions 

The capital cost allowance system groups the various types of property into numbered classes. In particular, the Mega Deduction would not apply to property in the following classes: 

• buildings and additions thereto included in Classes 1 and 3;
• property included in Classes 14 and 14.1, such as franchises, licenses and goodwill;
• property included in Class 51, including certain regulated natural gas distribution pipelines;
• certain vehicles included in Classes 10 and 10.1;
• depreciable property described in Schedules V and VI to the Income Tax Regulations. 

Exclusion from the Mega Deduction does not necessarily mean that no tax incentive is available. Property that was already eligible for certain measures allowing its cost to be deducted more quickly, such as immediate expensing or accelerated depreciation, would remain eligible for those measures. This would be the case, for example, for buildings used for manufacturing and processing under the temporary immediate expensing measure (2025 federal budget) and the Accelerated Investment Incentive (2025 federal budget and 2024 Fall Economic Statement). 

Restrictions and Special Measures 

Used Property 

Used property would be eligible only if it had never previously been owned by the taxpayer or non- arm’s length persons thereto and had not been acquired as part of a tax-deferred rollover transaction. 

Loss Restrictions 

Special rules would limit the ability for individuals, and partnerships the members of which include an individual, to create or increase a loss through the Mega Deduction. 

Liquefied Natural Gas (LNG) Facilities 

Class 47 liquefaction equipment used in a liquefied natural gas facility would benefit from a 100% capital cost allowance, provided that the deduction is limited to income from the facility’s liquefaction activities. This measure would apply to eligible property acquired on or after November 4, 2025.

Anticipated Impacts 

According to the government, the Mega Deduction would reduce the marginal effective tax rate applicable to new investment in Canada from 13.0% to 6.4%, compared with 16.9% in the United States and an average of 19.0% in OECD countries. 

The government estimates that the measure could eventually: 

• increase annual economic output by up to approximately $22 billion;
• support up to 80,000 additional jobs annually ten years from now;
• improve tax certainty surrounding long-term investment decisions. 

How to Prepare for the Mega Deduction 

Four factors will be particularly important in determining whether an investment may benefit from the Mega Deduction: the date the property is acquired, its capital cost allowance class, its prior use and the date on which it becomes available for use. 

Businesses contemplating significant investments should therefore review their acquisition and commissioning timelines to assess the measure’s potential impact, subject to the enactment of the final legislative rules. 

This new measure may, on the one hand, represent a significant growth lever to promote investment in eligible assets and, on the other hand, influence prospective purchasers of a business to favour a transaction involving all or part of its assets where immediate expensing would allow a taxpayer to significantly reduce its tax burden. 

For any questions about how your business could benefit from the Mega Deduction or the opportunities it could create in connection with your investments or transactions, please contact BCF’s taxation law team.