Key implementation point
UTPR deliberately excluded. SR&ED R&D credit (non-refundable portion) reduces covered taxes. Provincial tax variance requires careful ETR analysis.
Implementation detail
- 01 Canada enacted via the Global Minimum Tax Act, effective for fiscal years beginning on or after 31 December 2023.
- 02 UTPR not enacted — Canada signalled it would monitor UTPR adoption globally before proceeding.
- 03 DMTT (Canadian QDMTT) applies to Canadian constituent entities.
- 04 Canadian R&D credits (SR&ED): non-refundable portion of SR&ED credits reduces covered taxes.
- 05 Provincial corporate taxes vary significantly (8–16%) — GloBE ETR computation requires province-by-province analysis for Canadian-headquartered groups.
- 06 CRA (Canada Revenue Agency) issued guidance on registration, filing and calculation.
Enacted legislation
Global Minimum Tax Act (Bill C-69, Budget Implementation Act 2024 No. 1)
Official sources & further reading
Track Canada rules against your live MNE
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