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Update one-pager.html
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pnahachewsky authored Aug 12, 2024
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Expand Up @@ -147,7 +147,7 @@ <h2 class="panel-title">Related information</h2>
</div>
</div>
<div class="col-md-8">
<p>Members of qualifying MNE groups, may have to register and file a return with the Canada Revenue Agency (CRA).</p>
<p>With the introduction of the global minimum tax in Canada, members of qualifying multinational enterprise (MNE) groups may have to register and file a return with the Canada Revenue Agency (CRA) as early as <span class="nowrap">June 30, 2026</span>.</p>
<h2><strong>On this page</strong></h2>
<ul>
<li><a href="#gmt">Understand the global minimum tax</a></li>
Expand All @@ -162,9 +162,9 @@ <h2><strong>On this page</strong></h2>
<h2 id="gmt">Understand the global minimum tax</h2>
<!-- Background -->
<h3>Background</h3>
<p>As a members of the international organisation <abbr title="Organisation for Economic Co-operation and Development">OECD</abbr>/<abbr title="Group of 20">G20</abbr> Inclusive Framework, Canada has agreed to a global <span class="nowrap">two-part</span> plan to implement major reforms to the international tax system as it applies to multinational enterprises (MNEs). This plan aims to reduce the incentive for MNE groups to shift profits to <span class="nowrap">low-tax</span> jurisdictions and limit the erosion of the Canadian tax base.</p>
<p>The second part of this plan, called Pillar Two, introduces a 15% minimum tax that applies to large MNEs with revenues over <span class="nowrap"><abbr title="750 million euros">€750 million</abbr></span>. As a result, the Government of Canada has introduced the global minimum tax (GMT).</p>
<p>Members of qualifying MNE groups, may have to register and file a return with the Canada Revenue Agency (CRA).</p>
<p>As a members of the Organisation for Economic Co-operation and Development (OECD)/G20 Inclusive Framework, Canada has agreed to a global <span class="nowrap">two-part</span> plan to implement major reforms to the international tax system as it applies to multinational enterprises (MNEs). This plan aims to reduce the incentive for MNE groups to shift profits to <span class="nowrap">low-tax</span> jurisdictions and limit the erosion of the Canadian tax base.</p>
<p>The second part of this plan, called Pillar Two, introduces a 15% minimum tax that applies to large MNEs with revenues over <span class="nowrap">€750 million</span>. As a result, the Government of Canada has introduced the global minimum tax (GMT).</p>
<p>Members of qualifying MNE groups, may have to register and file a return with the CRA.</p>
<!-- Pillar Two -->
<h3>Pillar Two</h3>
<p><span class="nowrap">Pillar Two</span> builds on the OECD/G20 Base Erosion and Profit Shifting (BEPS) project. 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.</p>
Expand All @@ -173,8 +173,10 @@ <h3>The global minimum tax</h3>
<p>The GMT ensures a minimum ETR of 15% applies to profits of qualifying MNE groups for fiscal years that begin on or after <span class="nowrap">December 31, 2023</span>.</p>
<h3>The Global Minimum Tax Act (the&nbsp;Act)</h3>
<div id="gmta_dscr">
<p>The&nbsp;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 published by the OECD
<mark>from (?)</mark>
<p>The&nbsp;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 published by the
<mark>Organisation for Economic Co-operation and Development</mark>
from
<mark>(?)</mark>
time to time.</p>
</div>
<p>Part 2 of the&nbsp;Act implements aspects of the Pillar Two Income Inclusion <span class="nowrap">Rule (IIR)</span> found in Articles&nbsp;2.1 to&nbsp;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.</p>
Expand Down Expand Up @@ -263,20 +265,28 @@ <h2 id="cntct">Contact us</h2>
<h2 class="modal-title">A qualified IIR</h2>
</header>
<div class="modal-body">
<p>A qualified IIR, for a fiscal year, means an IIR 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 admissible)</p>
<p>A qualified IIR, for a fiscal year, means an IIR 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. (
<mark>RDIR (not defined on page)</mark>
admissible)</p>
</div>
</section>
<section id="utpr" class="mfp-hide modal-dialog modal-content overlay-def">
<header class="modal-header">
<h2 class="modal-title">A qualified UTPR</h2>
</header>
<div class="modal-body">
<p>A qualified UTPR, for a fiscal year, means a UTPR 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 admissible)</p>
<p>A qualified UTPR, for a fiscal year, means a
<mark>UTPR (not defined on page)</mark>
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. (
<mark>RPII (not defined on page)</mark>
admissible)</p>
</div>
</section>
<section id="gmta" class="mfp-hide modal-dialog modal-content overlay-def">
<header class="modal-header">
<h2 class="modal-title">Background on the GMT Act</h2>
<h2 class="modal-title">
<mark>Background on the GMT Act</mark>
</h2>
</header>
<div class="modal-body">
<section data-ajax-replace="#gmta_dscr"></section>
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