Jurisdictions › Canada
Enacted

Canada Pillar Two

Americas

Effective
Jan 2024
IIR local name
IIR
QDMTT local name
Domestic Minimum Top-up Tax (DMTT)
IIR
IIR
Enacted
UTPR
Not adopted
✕ Not adopted
QDMTT
Domestic Minimum Top-up Tax (DMTT)
Enacted
In development — This profile is provided for reference only and may contain inaccuracies. Always verify against official legislation and current OECD guidance.
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)
Track Canada rules against your live MNE

In Pillar2OS you can pull this jurisdiction's rules directly into your entity structure — automatically calculating top-up positions, flagging QDMTT obligations, and tracking rule changes as they happen across all your operating countries.

See it in the sandbox →