GloBE Country Guide: Canada

Summary

Status	Enacted Law
Law	On August 12, 2024, draft legislative proposals (the ‘2024 Draft Law’) were issued to provide for the Under-Taxed Profits Rule (UTPR) for fiscal years beginning on or after December 31, 2024 (as well as limited other amendments for the Fourth Set of OECD Administrative Guidance). On June 20, 2024, the Global Minimum Tax Act (included in the Budget Implementation Act 2024, No. 1) received royal assent. This includes provisions to implement an IIR and a QDMTT from December 31, 2023.
Effective Date	Accounting periods beginning on or after December 31, 2023
IIR	Yes (2024)
UTPR	Planned for 2025
QDMTT	Yes (2024)
Filing Deadlines	Standard
Safe Harbours	Transitional CbCR Safe Harbour, Simplified Calculations for Non-Material Constituent Entities Safe Harbour and the QDMTT Safe Harbour. The Transitional UTPR Safe Harbour is included in the 2024 Draft Law.

Legislation
General
Differences to Model Rules
Qualifying Domestic Minimum Top-Up Tax
Administration and Filing
Penalties

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Lee Hadnum

Lee is a qualified Chartered Accountant and Chartered Tax Adviser. A former Senior Tax Analyst at Bloomberg Tax, Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience. Lee's books have been recommended by The Times, The Guardian and The Telegraph.

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