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Canadian Tax Help – Tax Treatment of Reserves

Grant Gilmour

What is the tax treatment of reserves?

A common reserve to record on financial statements is an allowance for customer receivables that are considered to be bad debts. For tax purposes there are many additional types of reserves that may be claimed in calculating taxable income.


Below is a discussion of some common reserves that may be claimed in calculating taxable income.

Holdbacks and Long-Term Receivables

If a company has a holdback on a receivable, this holdback is reported as income on their financial statements but a reserve may be deducted from taxable income for this amount less the related payables and then added back in the year it is received. For more information on Holdbacks see our FAQ #184. In the same way, if a company enters a sales agreement in which it does not expect payment for at least two years, a reserve may be deducted from taxable income for this amount and then added back in the year the payment is received.

Counsel or Financing Fees

Only the portion of counsel or financing fees that relates to the tax year would be deducted from taxable income. For example, if a company paid $10,000 upfront as a financing fee to negotiate a five year mortgage, $10,000 may be expensed on the financial statements but for tax purposes only 1/5 of this should be included in the calculation of taxable income. A reserve of $8,000 is added back to taxable income and deducted over the next four years.

Goods or Services Delivered Post Year-End

For financial statement purposes, a company’s revenue recognition policy may be to recognize revenue at the time of sale. For tax purposes however, a reserve may be claimed to deduct from taxable income those sales for which goods or services are delivered after the year-end date often referred to as Deferred Revenue. The reserve would then be added back in the subsequent year.


If you have any questions about reserves, get in touch.


Grant has been in the CA business since 1988, starting his own practice in 1994. His tax expertise encompasses tax planning, international tax issues, and Scientific Research and Development tax credits. He is a graduate of the CICA In-Depth Tax Course and in 2012, Grant received the CA Community Service Award and the Scout Leader Medal.

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