Global Minimum Tax Act

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Sections2,396

• 1Short title

  This Act may be cited as the Global Minimum Tax Act.

• 2Definitions
• 2(1)

  The following definitions apply in this Act.

• 2(1)[p3]

  acceptable financial accounting standard means

• 2(1)[p3](a)

  Canadian generally accepted accounting principles (GAAP);

• 2(1)[p3](b)

  IFRS; or

• 2(1)[p3](c)

  the generally accepted accounting principles of

• 2(1)[p3](c)(i)

  Australia,

• 2(1)[p3](c)(ii)

  Brazil,

• 2(1)[p3](c)(iii)

  European Economic Area member states,

• 2(1)[p3](c)(iv)

  European Union member states,

• 2(1)[p3](c)(v)

  Hong Kong (Special Administrative Region of the People’s Republic of China),

• 2(1)[p3](c)(vi)

  Japan,

• 2(1)[p3](c)(vii)

  Mexico,

• 2(1)[p3](c)(viii)

  New Zealand,

• 2(1)[p3](c)(ix)

  People’s Republic of China,

• 2(1)[p3](c)(x)

  Republic of India,

• 2(1)[p3](c)(xi)

  Republic of Korea,

• 2(1)[p3](c)(xii)

  Singapore,

• 2(1)[p3](c)(xiii)

  Switzerland,

• 2(1)[p3](c)(xiv)

  United Kingdom, or

• 2(1)[p3](c)(xv)

  United States. (norme de comptabilité financière admissible)

• 2(1)[p22]

  adjusted covered taxes, of a constituent entity of an MNE group for a fiscal year, has the same meaning as in subsection 22(1). (impôts concernés ajustés)

• 2(1)[p23]

  adjustment year means a fiscal year in respect of which an adjustment is made to the GloBE income or loss or adjusted covered taxes, for the fiscal year, of a constituent entity of an MNE group or the jurisdictional adjusted covered taxes of an MNE group for the fiscal year because of the application of an ETR adjustment provision. (année d’ajustement)

• 2(1)[p24]

  aggregate asset gain, in respect of an election under subsection 18(23), means the net gain in a fiscal year from the disposition of local tangible assets by all of the constituent entities of an MNE group that are located in a particular jurisdiction, excluding any gain or loss on a transfer of assets between group entities. (profit cumulé sur cession d’actifs)

• 2(1)[p25]

  aggregate asset loss, in respect of an election under subsection 18(23), means the net loss in a fiscal year from the disposition of local tangible assets by all of the constituent entities of an MNE group that are located in a particular jurisdiction, excluding any gain or loss on a transfer of assets between group entities. (perte cumulée sur cession d’actifs)

• 2(1)[p26]

  allocable share has the same meaning as in subsection 15(2). (part à répartir)

• 2(1)[p27]

  allocated adjustment top-up amount has the same meaning as in subsection 30(5). (montant complémentaire d’ajustement attribué)

• 2(1)[p28]

  ancillary international shipping activity has the same meaning as in subsection 19(11). (activité de transport maritime international accessoire)

• 2(1)[p29]

  ancillary international shipping costs has the same meaning as in subsection 19(10). (coûts relatifs au transport maritime international accessoires)

• 2(1)[p30]

  ancillary international shipping income has the same meaning as in subsection 19(8). (revenu de transport maritime international accessoire)

• 2(1)[p31]

  ancillary international shipping revenue has the same meaning as in subsection 19(9). (recettes de transport maritime international accessoire)

• 2(1)[p32]

  authorized financial accounting standard, in respect of an entity, means a set of generally acceptable accounting principles permitted by the body responsible for prescribing, establishing or accepting accounting standards for financial reporting purposes in the jurisdiction where the entity is located. (norme de comptabilité financière agréée)

• 2(1)[p33]

  blended controlled foreign company tax regime, of a particular jurisdiction, means a controlled foreign company tax regime under which

• 2(1)[p33](a)

  the tax liability of an owner located in the particular jurisdiction is determined by reference to an aggregate of the income, losses and creditable taxes of other entities, located in one or more other jurisdictions, in which the owner holds an ownership interest;

• 2(1)[p33](b)

  the lowest rate that, if it were the corporate tax rate applicable in the one or more jurisdictions in which the other entities are located, would result in the tax charge in those jurisdictions being sufficient to prevent a tax charge on the owner under the controlled foreign company tax regime in respect of the other entities for a fiscal year, is less than the minimum rate; and

• 2(1)[p33](c)

  income of entities located in the particular jurisdiction is not taken into account. (régime fiscal intégré des sociétés étrangères contrôlées)

• 2(1)[p37]

  consolidated financial statements, of an entity, means

• 2(1)[p37](a)

  if the entity is not the ultimate parent entity of a group described in paragraph 10(2)(b), the financial statements of the entity prepared in accordance with an acceptable financial accounting standard, in which the assets, liabilities, income, expenses and cash flows of that entity and the entities in which it has a controlling interest are presented as those of a single economic unit;

• 2(1)[p37](b)

  if the entity is the ultimate parent entity of a group described in paragraph 10(2)(b), the financial statements of the entity that are prepared in accordance with an acceptable financial accounting standard;

• 2(1)[p37](c)

  if the entity has financial statements that would be described in paragraph (a) or (b) except that they are not prepared in accordance with an acceptable financial accounting standard, those financial statements, adjusted to prevent any material competitive distortions; and

• 2(1)[p37](d)

  if the entity does not prepare financial statements described in any of paragraphs (a) to (c), the financial statements — in which the assets, liabilities, income, expenses and cash flows of that entity and other entities are presented as those of a single economic unit — that would have been prepared in accordance with an authorized financial accounting standard that is

• 2(1)[p37](d)(i)

  an acceptable financial accounting standard, or

• 2(1)[p37](d)(ii)

  a financial accounting standard that is adjusted to prevent any material competitive distortions. (états financiers consolidés)

• 2(1)[p44]

  constituent entity has the same meaning as in subsection 11(1). (entité constitutive)

• 2(1)[p45]

  constituent entity-owner means a constituent entity that directly or indirectly holds an ownership interest in another constituent entity of the same MNE group. (entité détentrice de titres d’une entité constitutive)

• 2(1)[p46]

  controlled foreign company tax regime, of a particular jurisdiction, means a set of tax rules (other than an IIR) under which an entity (referred to in this definition as the “owner”) — that is located in the particular jurisdiction and that holds an ownership interest in another entity (referred to in this definition as the “controlled foreign company”) that is located in another jurisdiction — is subject to current taxation on its share of all or part of the income earned by the controlled foreign company, irrespective of whether that income is distributed on a current basis to the owner. (régime fiscal des sociétés étrangères contrôlées)

• 2(1)[p47]

  controlling interest means

• 2(1)[p47](a)

  an ownership interest in an entity such that the interest holder

• 2(1)[p47](a)(i)

  is required to consolidate the assets, liabilities, income, expenses and cash flows of the entity on a line-by-line basis in accordance with an acceptable financial accounting standard, or

• 2(1)[p47](a)(ii)

  would have been required to consolidate the assets, liabilities, income, expenses and cash flows of the entity on a line-by-line basis if the interest holder had prepared consolidated financial statements; or

• 2(1)[p47](b)

  the controlling interest that a main entity is deemed to hold in a permanent establishment under paragraph (2)(b). (participation conférant le contrôle)

• 2(1)[p52]

  cooperative means an entity that

• 2(1)[p52](a)

  collectively markets or acquires goods or services on behalf of its members; and

• 2(1)[p52](b)

  is subject to a tax regime in the jurisdiction in which it is located that is designed to ensure the tax neutrality of the cooperative in respect of the property or services of its members that are sold through the cooperative and property or services that are acquired by members through the cooperative. (coopérative)

• 2(1)[p55]

  core international shipping activity has the same meaning as in subsection 19(6). (activité de transport maritime international principale)

• 2(1)[p56]

  core international shipping costs has the same meaning as in subsection 19(5). (coûts relatifs au transport maritime international principal)

• 2(1)[p57]

  core international shipping income has the same meaning as in subsection 19(3). (revenu de transport maritime international principal)

• 2(1)[p58]

  core international shipping revenue has the same meaning as in subsection 19(4). (recettes de transport maritime international principal)

• 2(1)[p59]

  corporation includes an incorporated company, arrangement, association, organization or body. (société)

• 2(1)[p60]

  covered taxes has the same meaning as in subsection 23(1). (impôts concernés)

• 2(1)[p61]

  deductible dividend, in respect of a constituent entity that is subject to a deductible dividend regime, means

• 2(1)[p61](a)

  a distribution of profits, by the constituent entity to the holder of an ownership interest in the constituent entity, that is deductible from income for tax purposes of the constituent entity under the laws of the jurisdiction in which it is located; or

• 2(1)[p61](b)

  a patronage dividend distributed to a member of a cooperative. (dividende déductible)

• 2(1)[p64]

  deductible dividend regime means a tax regime that

• 2(1)[p64](a)

  is designed to yield a single level of taxation, on the owners of an entity, through a deduction from the income of the entity for distributions of profits to the owners (which, for this purpose, are considered to include patronage dividends); or

• 2(1)[p64](b)

  is applicable to cooperatives and exempts the cooperative from taxation. (régime des dividendes déductibles)

• 2(1)[p67]

  deemed distribution tax has the same meaning as in subsection 37(2). (impôt sur les distributions présumées)

• 2(1)[p68]

  deemed distribution tax recapture account means an account established and maintained in accordance with subsection 37(1). (compte de récupération de l’impôt sur les distributions présumées)

• 2(1)[p69]

  departing constituent entity, of an MNE group, means an entity that is a standard constituent entity of the MNE group located in a jurisdiction in a fiscal year in respect of which an election is made under subsection 37(1) and that has subsequently

• 2(1)[p69](a)

  left the MNE group; or

• 2(1)[p69](b)

  transferred substantially all of its assets to a recipient that is not, at the time of the transfer, a standard constituent entity of the MNE group located in the jurisdiction. (entité constitutive sortante)

• 2(1)[p72]

  disallowed accrual, of a constituent entity, means any movement in deferred tax expense recorded in the constituent entity’s financial accounts that relates to

• 2(1)[p72](a)

  an uncertain tax position; or

• 2(1)[p72](b)

  a distribution from a group entity in respect of the constituent entity. (accumulation non admise)

• 2(1)[p75]

  disposition recapture ratio has the same meaning as in subsection 37(6). (ratio de récupération de disposition)

• 2(1)[p76]

  disqualified refundable imputation tax means an amount of tax paid or accrued by a constituent entity (other than an amount of tax paid or accrued that is a qualified imputation tax) that is

• 2(1)[p76](a)

  refundable to the beneficial owner of a dividend or similar distribution by the constituent entity;

• 2(1)[p76](b)

  creditable against a tax liability (other than a tax liability in respect of the distribution) of the beneficial owner; or

• 2(1)[p76](c)

  refundable to, or creditable against a tax liability of, the constituent entity, in respect of the distribution. (impôt d’imputation remboursable non admissible)

• 2(1)[p80]

  domestic top-up amount has the same meaning as in subsection 52(1). (montant complémentaire national)

• 2(1)[p81]

  dual-listed arrangement means an arrangement entered into by the ultimate parent entities of two or more groups, under which

• 2(1)[p81](a)

  all or substantially all the businesses of the groups are combined by contract alone;

• 2(1)[p81](b)

  pursuant to contractual arrangements, the ultimate parent entities each make distributions (including dividends and distributions on a liquidation, if relevant) to their respective owners on the basis of a fixed ratio;

• 2(1)[p81](c)

  the activities of the groups are managed as those of a single economic unit;

• 2(1)[p81](d)

  the groups retain the separate legal identity they had before the arrangement was entered into;

• 2(1)[p81](e)

  ownership interests of at least one of the ultimate parent entities are quoted, traded or transferred independently on a securities market that is not the same as the securities market on which the ownership interests of another of the ultimate parent entities are quoted, traded or transferred independently; and

• 2(1)[p81](f)

  financial statements are prepared by one or more of the ultimate parent entities in which the assets, liabilities, income, expenses and cash flows of the groups’ entities are presented together as those of a single economic unit and those financial statements

• 2(1)[p81](f)(i)

  would be consolidated financial statements if the groups’ entities were included in a single group and the ultimate parent entity that prepared the financial statements were the ultimate parent entity of that group, and

• 2(1)[p81](f)(ii)

  are required by an applicable regulatory regime of a jurisdiction to be externally audited. (accord de double cotation)

• 2(1)[p90]

  effective tax rate has the same meaning as in subsection 29(1). (taux effectif d’imposition)

• 2(1)[p91]

  eligible distribution tax system, of a jurisdiction, means a corporate income tax system that is applicable in the jurisdiction that

• 2(1)[p91](a)

  generally imposes tax on the profits, or certain non-business expenses, of a corporation only when the corporation

• 2(1)[p91](a)(i)

  distributes those profits to its shareholders,

• 2(1)[p91](a)(ii)

  is deemed to distribute those profits to its shareholders, or

• 2(1)[p91](a)(iii)

  incurs those expenses;

• 2(1)[p91](b)

  imposes tax at a rate greater than or equal to the minimum rate; and

• 2(1)[p91](c)

  was in force on or before July 1, 2021. (régime admissible d’impôt sur les distributions)

• 2(1)[p98]

  eligible employee has the same meaning as in subsection 32(8). (employé admissible)

• 2(1)[p99]

  eligible payroll costs has the same meaning as in subsection 32(2). (frais de personnel admissibles)

• 2(1)[p100]

  eligible tangible asset has the same meaning as in subsection 32(14). (actif corporel admissible)

• 2(1)[p101]

  eligible tangible asset amount has the same meaning as in subsection 32(9). (montant de l’actif corporel admissible)

• 2(1)[p102]

  entity means a corporation, a partnership, a trust or any other arrangement, association, organization or body whether registered or unregistered for which separate financial accounts are prepared, but does not include a central, state or local government or its administration or agencies that carries out government functions. (entité)

• 2(1)[p103]

  ETR adjustment provision means paragraph 18(23)(c), subsection 25(6), paragraph 27(1)(b), subsection 27(4) or paragraph 37(4)(b) or (5)(b). (disposition d’ajustement du TEI)

• 2(1)[p104]

  excess negative tax expense has the same meaning as in subsection 29(4). (charge d’impôt négative excédentaire)

• 2(1)[p105]

  excess negative tax expense top-up amount has the same meaning as in subsection 31(2). (montant complémentaire de la charge d’impôt négative excédentaire)

• 2(1)[p106]

  excess profit has the same meaning as in subsection 30(4). (bénéfice excédentaire)

• 2(1)[p107]

  excluded costs has the same meaning as in subsection 32(3). (coûts exclus)

• 2(1)[p108]

  excluded dividends means dividends or other distributions received or accrued by a constituent entity in respect of an ownership interest in an entity, other than

• 2(1)[p108](a)

  a dividend or other distribution received or accrued in respect of

• 2(1)[p108](a)(i)

  an interest that is a short-term portfolio holding of the constituent entity on the earlier of

• 2(1)[p108](a)(i)(A)

  the date of the distribution, and

• 2(1)[p108](a)(i)(B)

  the date on which the constituent entity becomes entitled to the distribution, or

• 2(1)[p108](a)(ii)

  an ownership interest in an investment entity that is subject to an election under subsection 42(2); or

• 2(1)[p108](b)

  a dividend or other distribution received or accrued

• 2(1)[p108](b)(i)

  to the extent that it can reasonably be considered to be interest or another amount in respect of a debt component of a financial instrument, or

• 2(1)[p108](b)(ii)

  if it is

• 2(1)[p108](b)(ii)(A)

  made by another group entity, and

• 2(1)[p108](b)(ii)(B)

  treated as an expense for the purposes of determining the financial accounting income of the other group entity. (dividendes exclus)

• 2(1)[p119]

  excluded entity has the same meaning as in subsection 13(1). (entité exclue)

• 2(1)[p120]

  excluded equity gain or loss, of a constituent entity for a fiscal year, means the gain, profit or loss included in the financial accounting income of the constituent entity for the fiscal year arising from

• 2(1)[p120](a)

  gains and losses from changes in the fair value of an ownership interest, or from the impairment of an ownership interest, except for an interest that is a portfolio holding at the end of the fiscal year;

• 2(1)[p120](b)

  profit or loss in respect of an ownership interest included under the equity method of accounting; or

• 2(1)[p120](c)

  gains and losses from a disposition of an ownership interest, except for a disposition of an interest that is a portfolio holding immediately before the disposition. (profit ou perte sur capitaux propres exclu)

• 2(1)[p124]

  excluded taxes has the same meaning as in subsection 23(2). (impôts exclus)

• 2(1)[p125]

  filing constituent entity means

• 2(1)[p125](a)

  in respect of a qualifying MNE group for a fiscal year, a constituent entity of the MNE group that is

• 2(1)[p125](a)(i)

  located in Canada and required to file a GIR with the Minister, in respect of the MNE group for the fiscal year, in accordance with subsection 60(1) or 60(2),

• 2(1)[p125](a)(ii)

  a designated local entity (as appointed under paragraph 60(3)(a)) for the fiscal year, or

• 2(1)[p125](a)(iii)

  a qualifying foreign filing entity, as defined in subsection 55(1), for the fiscal year; and

• 2(1)[p125](b)

  in respect of an investment subgroup, joint venture group, minority-owned subgroup or minority-owned investment subgroup that is included in a qualifying MNE group for a fiscal year, the constituent entity that files the GIR in respect of the MNE group for the fiscal year. (entité constitutive déclarante)

• 2(1)[p131]

  financial accounting income has the same meaning as in subsection 17(1). (résultat net comptable)

• 2(1)[p132]

  financial accounting revenue has the same meaning as in subsection 33(3). (chiffre d’affaires comptable)

• 2(1)[p133]

  fiscal year, in respect of an MNE group, means

• 2(1)[p133](a)

  if paragraph (d) of the definition consolidated financial statements in this subsection applies in respect of the ultimate parent entity, the calendar year; and

• 2(1)[p133](b)

  in any other case, an accounting period for which the ultimate parent entity of an MNE group prepares its consolidated financial statements. (année financière)

• 2(1)[p136]

  fiscally transparent, in respect of an entity, means that under the laws of a jurisdiction, the income, expenditure, profit or loss of the entity is treated as if it were derived or incurred by the owner of the entity in proportion to the owner’s interest in the entity. (fiscalement transparent)

• 2(1)[p137]

  five-year election means an election, in respect of a particular fiscal year, to which the following rules apply:

• 2(1)[p137](a)

  the election applies to the particular fiscal year and, unless the election is revoked, each subsequent fiscal year;

• 2(1)[p137](b)

  the election cannot be revoked before the fifth fiscal year following the particular fiscal year;

• 2(1)[p137](c)

  if the election is revoked, no such election can subsequently be made until the fifth fiscal year following the revocation year; and

• 2(1)[p137](d)

  the election or any revocation of the election, as the case may be, must be made in the GIR for the first fiscal year in respect of which the election or revocation, as the case may be, is to be effective. (choix pour cinq ans)

• 2(1)[p142]

  flow-through entity means an entity to the extent it

• 2(1)[p142](a)

  is fiscally transparent under the laws of the jurisdiction where it was created; and

• 2(1)[p142](b)

  is not subject to a covered tax on its income or profit in another jurisdiction as a result of being tax resident in that jurisdiction. (entité intermédiaire)

• 2(1)[p145]

  flow-through tax benefits has the same meaning as in subsection 28(1). (avantages fiscaux intermédiaires)

• 2(1)[p146]

  general government means the central administration, agencies whose operations are under its effective control, state and local governments and their respective administrations. (administration publique)

• 2(1)[p147]

  GIR means an information return that contains the information, and is disseminated, in accordance with the Tax Challenges Arising from the Digitalisation of the Economy — GloBE Information Return (Pillar Two) published by the OECD on July 13, 2023, as amended from time to time, and that is

• 2(1)[p147](a)

  if required to be filed with the Minister by a constituent entity located in Canada under subsection 60(1) or 60(2) or subparagraph 60(3)(b)(i), the information return in prescribed form; and

• 2(1)[p147](b)

  in any other case, a substantially similar information return that is required to be filed in a jurisdiction other than Canada. (DRG)

• 2(1)[p150]

  GloBE Commentary means the commentary entitled Tax Challenges Arising from the Digitalisation of the Economy — Commentary to the Global Anti-Base Erosion Model Rules (Pillar Two), published by the OECD on March 14, 2022, as amended from time to time. (commentaires GloBE)

• 2(1)[p151]

  GloBE income, of a constituent entity for a fiscal year, means the positive amount, if any, of the constituent entity’s GloBE income or loss for the fiscal year. (revenu GloBE)

• 2(1)[p152]

  GloBE income or loss has the meaning assigned in section 16. (résultat net GloBE)

• 2(1)[p153]

  GloBE loss, of a constituent entity for a fiscal year, means the absolute value of the negative amount, if any, of the constituent entity’s GloBE income or loss for the fiscal year. (perte GloBE)

• 2(1)[p154]

  GloBE Model Rules means the model rules set out in the document entitled Tax Challenges Arising from the Digitalisation of the Economy — Global Anti-Base Erosion Model Rules (Pillar Two) published by the OECD on December 20, 2021. (règles GloBE)

• 2(1)[p155]

  GloBE reorganization means a transformation or transfer of assets and liabilities such as in a merger, demerger, liquidation or similar transaction, if

• 2(1)[p155](a)

  it is the case that

• 2(1)[p155](a)(i)

  if no consideration is provided for the transfer, the issuance of an equity interest as consideration for the transfer would have no economic significance because the transaction does not result in a change in the beneficial ownership of an entity, and

• 2(1)[p155](a)(ii)

  in any other case, the consideration for the transfer consists, in whole or in significant part, of

• 2(1)[p155](a)(ii)(A)

  if the transaction is a liquidation, the cancellation of equity interests of the entity that is the subject of the liquidation, and

• 2(1)[p155](a)(ii)(B)

  in any other case, equity interests issued by the transferee or an entity that is connected with the transferee;

• 2(1)[p155](b)

  the transferor’s gain or loss on the transfer is not subject, in whole or in part, to an income or profits tax in any jurisdiction; and

• 2(1)[p155](c)

  for the purpose of determining the transferee’s income or profits that are subject to an income or profits tax of the jurisdiction in which it is located, the transferee is required under the laws of that jurisdiction to use the transferor’s tax basis in respect of the transferred assets, adjusted to reflect any non-qualifying gain or loss in respect of the transfer. (réorganisation GloBE)

• 2(1)[p163]

  GloBE transition year, of an MNE group in respect of a jurisdiction, means the first fiscal year in which

• 2(1)[p163](a)

  a constituent entity of, or joint venture entity in respect of, the MNE group that is located in the jurisdiction is subject to a qualified IIR or qualified UTPR; and

• 2(1)[p163](b)

  subsection 33(1) or 47(2), section 45 or an equivalent provision under another qualified IIR or qualified UTPR does not apply for the jurisdiction. (année de transition GloBE)

• 2(1)[p166]

  governmental entity means an entity, if

• 2(1)[p166](a)

  it is part of or wholly owned by a government (including any political subdivision or local authority of the government);

• 2(1)[p166](b)

  its principal purpose is

• 2(1)[p166](b)(i)

  to fulfill a government function, or

• 2(1)[p166](b)(ii)

  to manage or invest the government’s assets through the making and holding of investments, asset management and related investment activities for the government’s assets;

• 2(1)[p166](c)

  it does not carry on a trade or business;

• 2(1)[p166](d)

  it is accountable to the government on its overall performance and provides annual information reporting to the government;

• 2(1)[p166](e)

  its assets vest in the government upon dissolution; and

• 2(1)[p166](f)

  if it distributes net earnings, the net earnings are distributed solely to the government with no portion of its net earnings inuring to the benefit of any private person. (entité gouvernementale)

• 2(1)[p175]

  group has the same meaning as in subsection 10(2). (groupe)

• 2(1)[p176]

  group entity, in respect of another entity or a group, means an entity that is a member of the same group. (entité du groupe)

• 2(1)[p177]

  high-tax counterparty means a constituent entity of an MNE group that is located in a jurisdiction that

• 2(1)[p177](a)

  is not a low-tax jurisdiction; or

• 2(1)[p177](b)

  would not be a low-tax jurisdiction if the effective tax rate of the MNE group for the jurisdiction were determined without regard to any income or expense recorded by an entity in respect of an intragroup financing arrangement. (contrepartie à imposition élevée)

• 2(1)[p180]

  hybrid entity, in relation to an owner, means an entity that is

• 2(1)[p180](a)

  not fiscally transparent in the jurisdiction where it is located; and

• 2(1)[p180](b)

  fiscally transparent in the jurisdiction where the owner is located. (entité hybride)

• 2(1)[p183]

  IFRS means International Financial Reporting Standards. (IFRS)

• 2(1)[p184]

  IIR means a law of a jurisdiction that may reasonably be considered to have been enacted with the intention of implementing, in whole or in part, Articles 2.1 to 2.3 of the GloBE Model Rules. (RDIR)

• 2(1)[p185]

  included revaluation method gain or loss, of a constituent entity for a fiscal year, means the net gain or loss, before covered taxes, for the fiscal year in respect of all property, plant and equipment that arises under an accounting method or practice that

• 2(1)[p185](a)

  periodically adjusts the carrying value of such property, plant and equipment to its fair value;

• 2(1)[p185](b)

  records the changes in value in other comprehensive income; and

• 2(1)[p185](c)

  does not subsequently report the gains or losses recorded in other comprehensive income through profit and loss. (profit ou perte inclus au titre de la méthode de réévaluation)

• 2(1)[p189]

  inclusion ratio has the same meaning as in subsection 15(3). (ratio d’inclusion)

• 2(1)[p190]

  Inclusive Framework means the jurisdictions of the OECD and Group of 20 (G20) Inclusive Framework on Base Erosion and Profit Shifting. (Cadre inclusif)

• 2(1)[p191]

  insurance investment entity means a particular entity, other than an investment fund or real estate investment vehicle,

• 2(1)[p191](a)

  that would be

• 2(1)[p191](a)(i)

  an investment fund if the definition investment fund in this subsection were read without reference to subparagraph (a)(i) and paragraphs (c) and (d) of that definition, or

• 2(1)[p191](a)(ii)

  a real estate investment vehicle if the definition real estate investment vehicle in this subsection were read without reference to subparagraph (b)(ii) of that definition;

• 2(1)[p191](b)

  that is primarily designed or established to generate investment income or gains to offset, or protect against an event or outcome that gives rise to, liabilities or losses associated with insurance or annuity contracts; and

• 2(1)[p191](c)

  in which each ownership interest is held by one or more entities each of which

• 2(1)[p191](c)(i)

  is a group entity in respect of the particular entity, and

• 2(1)[p191](c)(ii)

  is subject to a regulatory regime, in the jurisdiction in which it is established or managed, that is specific to entities engaged in the business of negotiating and entering into contracts of insurance or annuity or in activities ancillary to that business. (entité d’investissement d’assurance)

• 2(1)[p199]

  intermediate parent entity means a constituent entity of an MNE group (other than an ultimate parent entity, partially-owned parent entity, permanent establishment, investment entity or insurance investment entity) that holds, directly or indirectly, an ownership interest in another constituent entity of the MNE group. (entité mère intermédiaire)