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

Sign into your account to access this analysis

Not a Subscriber?

If you haven’t got a subscription you can sign up below

Already a Subscriber?

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.

Cookie	Duration	Description
cookielawinfo-checkbox-analytics	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics".
cookielawinfo-checkbox-functional	11 months	The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional".
cookielawinfo-checkbox-necessary	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary".
cookielawinfo-checkbox-others	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other.
cookielawinfo-checkbox-performance	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Performance".
viewed_cookie_policy	11 months	The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.

Belgium Issues a Draft 7 Page QDMTT Return for Consultation

Ireland GloBE Country Guide Updated for the 2024 Finance Bill

Portugal Enacts Pillar 2 Law, Bahamas and Cyprus Table Legislation in Parliament