CRA indicates that “fully electric” automotive equipment can include an electric cable railway car

A taxable Canadian corporation would acquire a vehicle - that used electricity supplied to it by an attached tether cable to power its fully electric motors and hydraulic pumps – to offload raw materials and move them by rail for offloading at a processing plant.

CRA noted that s. (d)(iv) of the definition of “clean technology property” in s. 127.45(1) referred inter alia to “a non-road zero-emission vehicle described in Class 56” and that Class 56 included “automotive equipment (other than a motor vehicle) that is fully electric.” In finding that the vehicle could qualify as a “clean technology property” if the other conditions were satisfied, CRA stated:

[T]he fact that the Property runs on rails and that its electricity is supplied by a tethered cable would not, in our view, prevent the Property from being considered to be automotive equipment that is fully electric.

Neal Armstrong. Summary of 3 October 2025 External T.I. 2025-1075051E5 under s. 127.45(1) - clean technology property - (d)(iv).