From 4fdb3a2e49cce4dc4dbda4af4f4b783e57c02290 Mon Sep 17 00:00:00 2001 From: pnahachewsky <83990925+pnahachewsky@users.noreply.github.com> Date: Tue, 10 Sep 2024 14:01:56 -0700 Subject: [PATCH] Create one-pager-v3.html --- en/one-pager-v3.html | 387 +++++++++++++++++++++++++++++++++++++++++++ 1 file changed, 387 insertions(+) create mode 100644 en/one-pager-v3.html diff --git a/en/one-pager-v3.html b/en/one-pager-v3.html new file mode 100644 index 0000000..bf1955b --- /dev/null +++ b/en/one-pager-v3.html @@ -0,0 +1,387 @@ + + + + + + +Global minimum tax - Canada.ca + + + + + + + + + + + + + + + + + + + + + +
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Government of Canada / Gouvernement du Canada + + + +
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Global minimum tax

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Source of the rules

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Bill C-69, which contains the Global Minimum Tax Act , received royal assent on June 20, 2024.

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Related information

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To reduce the incentive for multinational enterprise (MNE) groups to shift profits to low-tax jurisdictions and limit the erosion of the Canadian tax base, the Government of Canada introduced the global minimum tax.

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The tax requires qualifying MNE groups to pay a minimum effective tax rate (ETR) on their profits in every jurisdiction in which they operate.

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Members of qualifying MNE groups may have to register and file a return.

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On this page

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Learn about the global minimum tax

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Canada is one of the members of the Organisation for Economic Co-operation and Development (OECD) and Group 20 (G20) Inclusive Framework on Base Erosion and Profit Shifting. As a member, Canada has joined a two-pillar plan for international tax reform.

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The two-pillar plan

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Pillar Two consists of rules that are generally intended to be implemented through changes to each country’s domestic tax laws. Members of the Inclusive Framework are required to implement Pillar Two in a way that is consistent with the outcomes from the Global Anti-Base Erosion (GloBE) Model Rules, as well as the commentary and administrative guidance on the GloBE Model Rules.

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The Global Minimum Tax Act

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The Act implements key aspects of the Pillar Two rules in Canada based on the Global Anti-Base Erosion (GloBE) Model Rules, as well as the commentary and administrative guidance on the GloBE Model Rules. These references are approved by the Inclusive Framework and are published by the OECD from time to time.

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Part 2 of the Act implements aspects of the Pillar Two Income Inclusion Rule (IIR) found in Articles 2.1 to 2.3 of the GloBE Model Rules. As a global minimum tax it imposes liability for top-up tax on certain persons in respect of a qualifying MNE group.

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Part 3 of the Act allows Canada to retain taxing rights on income sourced in Canada. As a domestic minimum top-up tax it ensures any qualifying MNE groups with Canadian entities will pay the minimum rate of 15% tax in Canada in respect of those entities.

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The global minimum tax

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The global minimum tax is the result of the Budget 2022 proposal to implement Pillar Two along with a domestic minimum top-up tax that would apply to Canadian entities of MNEs that are within the scope of Pillar Two. The tax ensures that a minimum ETR of 15% applies to profits of qualifying MNE groups, in every jurisdiction in which they operate, for fiscal years that begin on or after December 31, 2023.

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Find out who must register and file

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A qualifying MNE group may be required to register with the CRA and file a return when:

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Once registered, the qualifying MNE group will need to file one or more of the following returns:

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One constituent entity or person may be appointed as the designated filing entity or person to file on behalf of all constituent entities or persons that must file with the CRA.

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Who must file a GloBE information return

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The following constituent entities of a qualifying MNE group must file a GloBE information return with the CRA:

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The constituent entities a qualifying MNE group that must file a GloBE information return with the CRA fall into one of the following categories:

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Who must file a global minimum tax return

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A person that is liable to pay tax under Part 2 or Part 3 of the Act must file a Part 2 or a Part 3 global minimum tax return with the CRA.

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Who must file a global minimum tax notification form

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If a qualifying foreign filing entity is filing the GloBE information return for the MNE group with the tax authority of the jurisdiction where it is located, each constituent entity located in Canada must file a global minimum tax notification form with the CRA.

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Register with the CRA

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How to register

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Information on registration will be available at a later date.

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When to register

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Information on registration will be available at a later date.

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File a global minimum tax return

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When to file

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The forms must be filed by the later of June 30, 2026. Depending on its fiscal year-end, an entity may file by one of the following later deadlines:

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    18 months after the last day of the fiscal year, if it is the first fiscal year that an entity of the qualifying MNE groups is subject to:

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    15 months after the last day of the fiscal year, in any other case

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How to file

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Information on filing will be available at a later date.

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Contact us

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Contact the CRA if you have a general question about the global minimum tax or if you would like to ask for a technical interpretation related to the Act.

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What are you contacting the CRA about?

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A qualified IIR

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A qualified IIR, for a fiscal year, means an IIR + (not defined in overlay) + that has qualified status (including transitional qualified status) for the fiscal year as determined by the Inclusive Framework and published on the website of the OECD. (RDIR + (not defined on page) + admissible)

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A qualified UTPR

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A qualified UTPR, for a fiscal year, means a UTPR + (not defined on page - Undertaxed Payments Rule?) + that has qualified status (including transitional qualified status) for the fiscal year as determined by the Inclusive Framework and published on the website of the OECD. (RPII + (not defined on page) + admissible)

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