Summary Policy

Date
September 3, 2003 (Revised November 23, 2005)

Reference Number
CSP-S16

Key Words
Substantially all

Policy Statement

The Canada Revenue Agency's position is that the expression "substantially all" used in the Income Tax Act means 90% or more.

References

• Business, CSP-B02.
• Related Business, CSP-R05.
• Income Tax Act, R.S.C. 1985 (5^th supp.) c. 1.