September 15, 2026

Ottawa Will Help Pay for Your Private AI Stack

The mega-deduction announced this morning writes off compute and software in year one. SR&ED now refunds 35% on up to $6 million. RAII finances half a project at 0%. Layered properly, the programs change what a private AI stack actually costs a Canadian firm.

On September 15, Prime Minister Mark Carney announced the Productivity Mega-Deduction: businesses can now write off 100% of eligible new investment in the first year the asset is available for use, permanently, for costs incurred from that day forward.1 The eligible classes read like a private AI stack's bill of materials: computer equipment, software, R&D, patents.1 The share of capital investment that can be expensed immediately jumps from roughly 15% to over 65%.3

Here's the thing this announcement doesn't say: it isn't arriving alone. It lands on top of an SR&ED program that was just expanded by Bill C-15, and a $200 million regional AI fund that most operators have never heard of.46 Let's walk through the three programs, then put real numbers on a $1 million build, then lay out the order of operations, because sequencing is where firms leave money on the table.

0%
First-year write-off, new eligible capital
Productivity Mega-Deduction
0%
Refundable credit on R&D, up to $6M
SR&ED, expanded Mar 2026
$0M
Max per project at 0% interest
RAII, up to 50% of costs

The three programs, in one pass

The Productivity Mega-Deduction is immediate expensing made permanent. Instead of depreciating a GPU server over years under capital cost allowance, the full cost comes off taxable income in year one. It applies to eligible costs incurred on or after September 15, 2026, at an estimated fiscal cost of $36 billion over five years, and the government's own framing is that it drops Canada's marginal effective tax rate on new business investment below every major economy.23

"Canada's marginal effective tax rate on new business investment will fall from roughly 13% to 6.4% – the lowest of any major economy in the world and less than half the rate in the United States."

— Prime Minister's Office, September 15, 2026
Fig. 1

What can be written off immediately

0%20%40%60%80%
Before
After Sep 15, 2026
PMO news release; The Globe and Mail, Sep 15, 2026
Share of capital investment classes eligible for immediate first-year expensing, before and after the September 15 announcement.

SR&ED is the one Canadian founders think they know, and the 2026 version is meaningfully better than its reputation. Bill C-15 doubled the enhanced expenditure limit: the 35% refundable credit now applies to up to $6 million of qualifying R&D spending a year, the taxable-capital phase-out was raised to $15–75 million, eligible Canadian public corporations gained access to the refundable rate, and capital equipment used at least 90% for eligible R&D is claimable again for the first time in over a decade.45 Refundable means a cheque, not a carry-forward; a pre-profit company gets cash. The catch is real, though: SR&ED pays for experimental development, work with genuine technological uncertainty. Fine-tuning evaluation methods, novel retrieval architectures, and serving optimizations can qualify. Installing a chatbot doesn't.

RAII, the Regional Artificial Intelligence Initiative, is the sleeper. It's a $200 million envelope delivered through the regional development agencies for projects that commercialize or adopt AI, with intake open through 2028.6 For businesses it isn't a grant, and it's worth being precise about that: it's an interest-free repayable contribution covering up to 50% of eligible project costs, from $250,000 to $5 million, repaid at 0% over five years starting a year after the project ends, with no security taken.6 Unsecured 0% money with a multi-year runway is a financing instrument most CFOs would take every day of the week.

A $1M stack, with the layers applied

Take a concrete case: an Alberta manufacturer, a Canadian-controlled private corporation, builds a $1 million private AI stack this fall. Say the bill splits into $450K of GPU and server hardware, $100K of software and licences, $150K of integration engineering, and $300K of genuine experimental development, the model-adaptation and serving work where outcomes are actually uncertain. Assume it pays the combined 23% general corporate rate and has the taxable income to absorb a deduction.

The layers apply like this, and the arithmetic is worth showing. The mega-deduction expenses the $550K of hardware and software in year one: at 23%, that's $126,500 of tax that doesn't get paid. The $300K of experimental development earns the 35% refundable SR&ED credit: a $105,000 cheque, payable even in a loss year. That's $231,500 back inside roughly twelve months, about 23 cents on every dollar, before touching provincial R&D credits. And RAII can carry up to half the project, $500,000, as unsecured 0% financing; at a 7% commercial borrowing rate, that's around $35,000 a year of interest that never gets paid.

Fig. 2

Where the $1M lands in year one

50%
Financed at 0% by RAII, repaid from year 4
Back in year one (tax saving + SR&ED refund)$232K23%
Financed at 0% by RAII, repaid from year 4$500K50%
Own capital$269K27%
Worked example · program parameters from PMO, KPMG, PrairiesCan; assumptions in prose
Year-one position of the illustrative $1M Alberta build. Cash back combines the mega-deduction tax saving ($126.5K at a 23% rate) and the SR&ED refundable credit ($105K). No asset is counted in both layers.

Notice what makes the stack work: the three programs don't overlap, they interlock. The mega-deduction takes the capital, SR&ED takes the R&D labour, RAII takes the financing. Nothing is double-counted, which is exactly how a reviewer wants to see it.

The order of operations

Sequencing matters more than any single program. Talk to the regional development agency before incurring costs, not after, and keep the SR&ED evidence trail from day one rather than reconstructing it at filing time.

Fig. 3
One project, three programs

How the claims sequence

  1. Now

    Split the budget into capital (mega-deduction), experimental development (SR&ED), and total eligible project costs (RAII). The split drives everything downstream.

  2. Now

    RAII intake is open through December 31, 2028. Submit the expression of interest before incurring project costs, and confirm which costs your region's agency will recognize.

  3. Day 0

    Costs incurred on or after September 15, 2026 qualify for the mega-deduction in the year the assets are available for use.

  4. Yr 0-3

    RAII projects can run up to 3 years. Contemporaneous records of hypotheses, experiments, and failures are what make the SR&ED claim survivable.

  5. T2 time

    The claim rides the corporate return; the refundable credit arrives as cash for qualifying CCPCs and eligible public corporations.

  6. End +1yr

    Monthly installments at 0% over five years, unsecured, no penalty for early repayment.

PrairiesCan RAII program pages; CRA SR&ED filing rules; PMO announcement
The sequence for stacking the three programs on one project. RAII terms per PrairiesCan; other regions' agencies run the same initiative.

What this doesn't say

Honest caveats, because a primer that skips them isn't one. The mega-deduction is nine hours old as this publishes: the announcement is specific, but the legislative text isn't tabled yet, so final class definitions can shift.2 A deduction is only worth its rate times your taxable income; a company with no profit banks the SR&ED refund but waits on the write-off. RAII money must be repaid, on schedule, whether or not the project delivered. And SR&ED eligibility is a technical test, not a vibe; plenty of AI integration work is valuable and still doesn't qualify. The worked example is illustrative, provincial rates and credits vary, and none of this is tax advice; the right structure for your firm is a conversation with your accountant.

Key takeaways

  • 01The mega-deduction makes compute and software 100% deductible in year one, permanently, for costs from September 15, 2026 onward.
  • 02SR&ED after Bill C-15 refunds 35% on up to $6M of qualifying R&D, and R&D capital equipment is claimable again.
  • 03RAII is unsecured 0% financing for up to half an AI project ($250K–$5M), repaid over five years starting a year after project end.
  • 04Stacked cleanly on an illustrative $1M build: about $231K back in year one and $500K financed interest-free, with no double counting.

Sources

  1. Prime Minister's Office, "Prime Minister Carney introduces new Productivity Mega Deduction" (September 15, 2026): https://www.pm.gc.ca/en/news/news-releases/2026/09/15/prime-minister-carney-introduces-new-productivity-mega-deduction
  2. Finance Canada, "Government of Canada introduces new Productivity Mega Deduction" (September 15, 2026): https://www.canada.ca/en/department-finance/news/2026/09/government-of-canada-introduces-new-productivity-mega-deduction-to-boost-canadas-advantage-as-the-most-competitive-g7-country-for-new-business-inve.html
  3. The Globe and Mail, investment summit coverage (September 15, 2026): https://www.theglobeandmail.com/business/article-canada-investment-summit-live-updates-september-15/
  4. KPMG in Canada, "Canada's SR&ED program enters a new era" (2026): https://kpmg.com/ca/en/insights/2026/02/canadas-sr-and-ed-program-enters-a-new-era.html
  5. BDO Canada, "SR&ED tax credit program significantly enhanced as Bill C-15 passes" (2026): https://www.bdo.ca/insights/sr-ed-program-enhancements-and-updates-draft-legislation-released
  6. PrairiesCan, Regional Artificial Intelligence Initiative program pages (accessed September 15, 2026): https://www.canada.ca/en/prairies-economic-development/services/funding/regional-artificial-intelligence-initiative.html