Members of qualifying MNE groups, may have to register and file a return with the Canada Revenue Agency (CRA).
+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 June 30, 2026.
As a members of the international organisation OECD/G20 Inclusive Framework, Canada has agreed to a global two-part 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 low-tax jurisdictions and limit the erosion of the Canadian tax base.
-The second part of this plan, called Pillar Two, introduces a 15% minimum tax that applies to large MNEs with revenues over €750 million. As a result, the Government of Canada has introduced the global minimum tax (GMT).
-Members of qualifying MNE groups, may have to register and file a return with the Canada Revenue Agency (CRA).
+As a members of the Organisation for Economic Co-operation and Development (OECD)/G20 Inclusive Framework, Canada has agreed to a global two-part 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 low-tax jurisdictions and limit the erosion of the Canadian tax base.
+The second part of this plan, called Pillar Two, introduces a 15% minimum tax that applies to large MNEs with revenues over €750 million. As a result, the Government of Canada has introduced the global minimum tax (GMT).
+Members of qualifying MNE groups, may have to register and file a return with the CRA.
Pillar Two 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.
@@ -173,8 +173,10 @@The GMT ensures a minimum ETR of 15% applies to profits of qualifying MNE groups for fiscal years that begin on or after December 31, 2023.
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 published by the OECD - from (?) +
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 published by the + Organisation for Economic Co-operation and Development + from + (?) time to time.
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.
@@ -263,7 +265,9 @@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)
+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 (not defined on page) + admissible)