Who must file a return or notification
Under the Global Minimum Tax Act, members of a qualifying multinational enterprise (MNE) group that meet the filing requirements must file the prescribed returns or notification with the Canada Revenue Agency (CRA).
Prescribed returns or notification
At least one member of a qualifying MNE group must file one or more of the following returns or notification:
- GloBE Information Return (GIR)
- Global Minimum Tax Return
- GIR Notification
A constituent entity or person may be appointed to file on behalf of all constituent entities or persons that must file with the CRA.
Who must file a GIR Notification or a GIR
To determine which entities must file a GIR Notification or a GIR with the CRA, use the following interactive questions.
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When an MNE group is not filing a GIR in a jurisdiction other than Canada
If the MNE group appoints a designated filing entity located in Canada:
- No constituent entity located in Canada needs to file GIR Notification
- The designated filing entity must file the GIR
If no designated filing entity is appointed and the ultimate parent entity of the MNE group is located in Canada:
- No constituent entity located in Canada needs to file GIR Notification
- The ultimate parent entity must file the GIR
If an ultimate parent entity or designated filing entity located outside Canada has already filed the GIR directly with the CRA:
- No constituent entity located in Canada needs to file GIR Notification
- No constituent entity located in Canada needs to file the GIR
However, if no GIR has been filed by a designated filing entity or ultimate parent entity of the MNE group located in Canada, or a designated filing entity or ultimate parent entity located outside of Canada:
- No constituent entity located in Canada needs to file GIR Notification
- Each constituent entity located in Canada or an appointed designated local entity must file the GIR
When an MNE group is filing a GIR in a jurisdiction other than Canada
If a qualifying foreign filing entity is filing the GIR in the jurisdiction where it is located:
- Each constituent entity located in Canada or an appointed designated notification entity must have previously filed a GIR Notification
- No constituent entity located in Canada needs to file the GIR
However, if the qualifying foreign filing entity has not successfully filed the GIR in the jurisdiction where it is located, then both a GIR Notification and a GIR must be filed as follows:
- Each constituent entity located in Canada or an appointed designated notification entity must have previously filed a GIR Notification
- Each constituent entity located in Canada or an appointed designated notification entity must file the GIR
Who must file a Global Minimum Tax Return
Each person who has tax liability under Part 2 (global minimum tax) or Part 3 (domestic minimum top-up tax) of the Act, or the appointed Canadian filing entity, must file a Global Minimum Tax Return with the CRA.
Filing on behalf of other entities
If more than one person in your MNE group is required to file a Global Minimum Tax Return for a fiscal year, one of those persons who is resident in Canada may be appointed as a Canadian filing entity to file the return on behalf of all persons that are required to file it.
It is essential that you register for a global minimum tax program account for each constituent entity that has a liability under the Act.
To learn more, refer to Who must register
What is a designated local entity
A designated local entity refers to a Canadian constituent entity within an MNE group that is designated by the other Canadian constituent entities of the group to file the GIR on their behalf.
What is a designated filing entity
A designated filing entity refers to a constituent entity within an MNE group that has been appointed by the group in substitution for the ultimate parent entity to submit the GIR on behalf of the group. This entity must meet both of the following conditions:
- The entity must have been given everything it may reasonably require to comply with the GIR filing obligations
- The entity must be located in a jurisdiction that has a qualified Income Inclusion Rule (IIR) or a qualified UTPR
What is a designated notification entity
If there is a qualifying foreign filing entity of a qualifying MNE group for a fiscal year, and more than one constituent entity of the MNE group is required to notify the CRA, one of those constituent entities located in Canada may be appointed as a designated notification entity.
In such a case, the appointed designated notification entity will file the GIR Notification on behalf of all the other Canadian constituent entities.
What is an ultimate parent entity
An ultimate parent entity is an entity that either:
- Directly or indirectly holds a controlling interest in other entities and is not controlled by any other entity
- Has one or more permanent establishments that are not located in the jurisdiction in which the entity is located
What is a qualifying foreign filing entity
A qualifying foreign filing entity is an ultimate parent entity or a designated filing entity of the MNE group that is located in a foreign jurisdiction and that is obligated to file a GIR with the tax authority of the foreign jurisdiction, provided that the foreign jurisdiction has a qualifying competent authority agreement that is in effect on or before the GIR exchange date for the fiscal year.
Canada must be a party to the agreement for the entity to be a qualifying foreign filing entity.