Global minimum tax: Questions and Answers

Interpretations

Question 1: Where a multinational enterprise (MNE) group filed, and later amended, a country-by-country (CbC) report in Canada, can the amended CbC report be relied on for the purposes of the transitional country-by-country reporting (CbCR) safe harbour (TCSH)?

Answer: Yes, an amended CbC report could be relied on for the TCSH election.
For example, if an MNE group preparing its GloBE Information Return (GIR) discovers that its CbC report was unintentionally filed with incorrect information and it subsequently files an amended CbC report before it files its GIR for that fiscal year, the MNE group may rely on the amended CbC report for the purposes of electing the TCSH for that fiscal year, provided it meets the definition of a qualified CbC report in subsection 47(1) of the Global Minimum Tax Act. 

Please refer to External Technical Interpretation 2025-1073271E5 for more details.

Question 2: The information reported in the CbC report of an MNE group can affect its eligibility for the TCSH with respect to a particular jurisdiction in a given fiscal year. Generally, reported entities in the CbC report are based on where they are tax resident. Should a Canadian partnership be reported in a qualified CbC report as a stateless entity or as a resident of Canada, and should a U.S.-owned Single-Member LLC be reported as a stateless entity or as a resident of the U.S.?

Answer:

Canadian partnership

The Canada Revenue Agency (CRA) does not consider a Canadian partnership to be a tax resident in Canada for CbCR purposes, except where paragraph 233.8(2)(b) of the Income Tax Act applies (that is, when the partnership is the ultimate parent entity (UPE) and was organized under the laws of Canada). The Canadian partnership’s data, to the extent they are not attributable to a permanent establishment, should be reported in Table 1 of Form RC4649, Country-by-Country Report, on the line for stateless entities (coded as X5). As well, any partners that are also constituent entities within theMNE group should include their share of the Canadian partnership’s items in Table 1 in their jurisdiction of tax residence, with any explanatory information included in Table 3.

U.S.-Owned Single-Member LLC

The CRA would generally expect a U.S.-Owned Single-Member LLC to be reported on Form RC4649 as having its tax jurisdiction in the United States, and its data to be reported on the United States line in Table 1. The OECD guidance on double-reporting the items of a tax-transparent partnership with no tax residency should not apply in this context because the U.S.-Owned Single-Member LLC is reported as a tax resident in the United States and is not regarded as a partnership.

Please refer to External Technical Interpretation 2025-1073261E5 for more details.

Question 3:Stateless entities and stateless permanent establishments are each deemed to be located in a notional jurisdiction where no other entity or permanent establishment is located. Is the TCSH election available for the notional jurisdictions of stateless entities?

Answer: The TCSH election is not available for the notional jurisdictions of stateless entities, consistent with the guidance in paragraph 38 of Chapter 1 of Tax Challenges Arising from the Digitalisation of the Economy - Consolidated Commentary to the Global Anti-Base Erosion Model Rules.

Please refer to External Technical Interpretation 2025-1072361E5 for more details.

Scope and application

Question 4: What is the prescribed form and manner in which a constituent entity (or filing constituent entity) may make the election to apply the simplified effective tax rate (ETR) test under section 47(2) of the Global Minimum Tax Act for purposes of the TCSH?

Answer: The GIR is currently available on the OECD website, at the following link: Global Anti-Base Erosion Model Rules (Pillar Two) | OECD. The GIR schema released by the CRA closely aligns with this document.

Generally, Section 2 of the GIR covers jurisdictional safe harbours and exclusions. Specifically, the election to apply the simplified ETR test under the TCSH is identified in section 2.2.1.1.1, as “Transitional CbCR Safe Harbour –Simplified ETR test.” For the simplified ETR test, the filing constituent entity must report the following information in section 2.2.1.3(a) of the GIR:

• profit (loss) before income tax for the jurisdiction as reported in the qualified CbC report of the MNE group (or qualified financial statements for members of Joint Venture (JV) groups) for the reporting fiscal year and in line with the methodologies set out in the document, Safe Harbours and Penalty Relief: Global Anti-Base Erosion Rules (Pillar Two)
• simplified covered taxes of the relevant constituent entities or members of JV groups, as defined in the above Safe Harbours and Penalty Relief document for the reporting fiscal year 

For the purposes of claiming this safe harbour, no other additional forms are needed as the GIR contains the required information.

Question 5: How are GIRs exchanged between Canada and other jurisdictions? What are the filing obligations of a Canadian constituent entity when its non‑Canadian UPE files the GIR in a foreign jurisdiction?

Answer: Canada supports the exchange of GIRs through international agreements, including the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA), published by the OECD in January 2025.
The GIR MCAA facilitates the automatic electronic exchange of GIRs between participating jurisdictions. When it is in effect between Canada and another jurisdiction, it qualifies as a Qualified Competent Authority Agreement (QCAA) under the GloBE Model Rules. For the agreement to apply, both jurisdictions must sign the GIR MCAA and identify each other as exchange partners.
Canada has signed the GIR MCAA. The most up-to-date information on participating jurisdictions and exchange relationships is available on the OECD website.

Where a non-Canadian UPE files a GIR in a foreign jurisdiction, a Canadian constituent entity is generally required to file a GIR Notification with the CRA by the applicable due date.

If the GIR is not exchanged with Canada by the exchange deadline, the CRA will notify the Canadian constituent entity (or designated entity), which must then file the GIR within 30 days of receiving that notification.

Question 6: Company A is the UPE of Canadian MNE Group A that acquired a subsidiary in mid-year 2024, whose revenue has been included in MNE Group A’s consolidated revenue for financial reporting purposes from the acquisition date. Are the pre-acquisition revenues of the subsidiary in 2020, 2021, 2022, and 2023 required to be added retroactively to MNE Group A’s consolidated revenue for each of those years to determine if two of the most recent four fiscal years have met the €750 million threshold for global minimum tax filing purposes?

Answer: Yes, under subsection (9)1 of the Global Minimum Tax Act, a qualifying MNE group is an MNE group that reports revenues of at least €750 million in the consolidated financial statements of its ultimate parent entity in at least two of the four fiscal years immediately preceding the relevant fiscal year. In addition, the group must not be made up entirely of excluded entities for that fiscal year. 

Subsection 9(3) of the Global Minimum Tax Act applies to an MNE group formed by a merger. The phrase “formed as a result of a merger” in this subsection is not intended to mean that the MNE group necessarily did not exist prior to the merger.

Under subsection 9(3), the revenues of all entities or groups that later become part of an MNE group are combined for each pre‑merger fiscal year. These revenues are taken from the entities’ or groups’ own financial statements and are treated as if they were revenues of the MNE group for that year. This combined revenue is then used to determine whether the MNE group meets the €750 million revenue threshold required to qualify as a “qualifying MNE group” under subsection 9(1) or (4).

Because the accounting periods used in these pre‑merger financial statements may not match the MNE group’s fiscal year, subsection 9(3) requires revenues to be allocated on a “just and reasonable” basis. This applies where financial statements span more than one pre‑merger fiscal year or only partially overlap with a pre‑merger fiscal year.

As a result, MNE Group A would be required to include the corresponding pre-acquisition revenues of the newly acquired subsidiary in determining whether it meets the €750 million revenue threshold in any particular fiscal year.

Question 7: Can a natural person be liable to pay tax under the Global Minimum Tax Act?

Answer: Yes, a natural person can be liable to pay tax under the Act.

Specifically, the statutory framework may impose a tax liability on natural persons under subparagraph 14(1)(b)(ii) in respect of the global minimum tax (Income Inclusion Rule) and subparagraph 51(1)(c)(ii) in respect of the domestic minimum top-up tax.

Registration

Question 8: Is a social insurance number (SIN) mandatory to register for a global minimum tax program account (PT program account)? If so, how should a Canadian constituent entity with no Canadian-resident officers or directors register?

Answer: Yes, the SIN is mandatory with two exceptions: where all owners are non-resident or where the business is owned by another business, for example, where the owner is a corporation or partnership. For these exceptions, the taxpayer may register by contacting the CRA’s Business Enquiries line at 1-800-959-5525 (Outside Canada or United States call collect 1-613-940-8497), Monday to Friday from 8:00 am to 8:00 pm Eastern Time.

While the Business Registration Online (BRO) web page states that, effective November 3, 2025, the CRA will no longer accept business number or CRA program account registrations by telephone and the taxpayer must register online using BRO, certain exceptions apply. A Canadian constituent entity with only non-resident owners is one such exception.

When calling, the taxpayer should inform the CRA agent that the taxpayer is registering for a PT program account for a Canadian business with only non-resident owners, which qualifies as an exception where registration cannot be completed using BRO.

Question 9: The name and social insurance number (SIN) of an officer or director are generally needed to register for the PT program account. For a bank or public company, who could be the signing officer? Does it have to be the CEO, or can it be another senior executive? Can it be the same person signing the corporate income tax return?

Answer: The signing officer can be a senior executive with authority on the account, such as a CEO or CFO. If a different individual is required to be added who is not listed as an officer in the applicable corporate registry, or the information needs to be updated, a request to the CRA to add other officers should be submitted. For options to update this information, go to Access to corporate tax information - Canada.ca. Refer to the “Add or update corporation and director information” section.

Question 10: With the increasing use of global business centres to process tax filings for Canadian subsidiaries of multi-national corporations, is there any ability to allow non-Canadians to manage registrations or communications or both through  My Business Account (MyBA)?

Answer: No, not currently.

Question 11: If a Canadian constituent entity does not have taxes payable under parts 2 or 3 of the Global Minimum Tax Act (that is, no top-up tax) and designates another Canadian constituent entity to file the GIR Notification on their behalf, are they still required to register for a PT program account? 

Answer: No, the constituent entity only needs to register for a PT program account if the constituent entity will file a return or notification, or if the constituent entity is liable for tax under parts 2 or 3 of the Act.

Question 12: Does an entity have to register for a PT program account every year?

Answer: No, it is a one-time registration to obtain a PT account for a particular entity, similar to other CRA program accounts (like GST/HST, payroll, or income tax). Once registered, the entity (or person) will use that same account for their annual returns, notifications, and ongoing compliance, and will not have to register each year.

Filing

Question 13: What happens if a taxpayer loses the digital access code (DAC) after PT registration? Can a replacement be requested, will the DAC be available in MyBA, and can the same DAC be used more than once (for example, to file an amendment for the same year)?

Answer: If a taxpayer loses the DAC after registering for a PT program account, a request to replace the DAC can be made in several ways. The replacement request may be submitted through the online DAC web page, Need a Digital Access Code? or the helpdesk. A taxpayer may also create a DAC request/response service, as outlined in the Global Minimum Tax Submission Guide, using json or xml.

The DAC will also be available in MyBA.

In addition, the same DAC can be used multiple times for submissions within the same calendar year for the same account type, including situations where a taxpayer needs to file an amended return or notification for the same year.

Question 14: What are the guidelines on acceptable file sizes and record counts to help MNEs prepare their submissions in compliance with CRA requirements and avoid potential filing issues?  

Answer: The file size limit is 100MB (104,857,600 bytes). This information can be found in Appendix D of the Global Minimum Tax Submission Guide. There are error messages in Appendix G that a filer would receive for the GloBE Information Return (GIR) Notification (2215), Global Minimum Tax Return (2115) and GIR (2415) if the submission goes over 100MB.

Question 15: Will the taxpayer receive a confirmation when filing a global minimum tax return or notification?

Answer: Yes, the taxpayer will receive a confirmation number containing up to eight characters.

Question 16: What are the filing obligations under the Global Minimum Tax Act for a qualifying MNE group that has a UPE not located in Canada, and one or more constituent entities located in Canada with no taxes payable under parts 2 and 3 of the Act?

Answer: If a constituent entity of a qualifying MNE group has no taxes payable under parts 2 and 3 of the Act, it is not required to file a global minimum tax return (Part 2 or Part 3 tax return) in Canada for that fiscal year.

If a qualifying foreign filing entity of the MNE group has filed the GIR in a foreign jurisdiction, the MNE group can designate a Canadian constituent entity to file the GIR Notification with the CRA. If no designated entity is appointed to file the GIR Notification in Canada, then all Canadian constituent entities are required to file the GIR Notification with the CRA.

If the GIR has not been filed in a foreign jurisdiction by a qualifying foreign filing entity, the MNE group can designate a Canadian constituent entity to file the GIR with the CRA. If no designated entity is appointed to file the GIR in Canada, then all Canadian constituent entities are required to file the GIR with the CRA.
For the GIR and GIR Notification, only the entities that are filing with the CRA are required to register for a PT program account. While not applicable in this situation, when a Part 2 or Part 3 tax return is required to be filed, all relevantCanadian constituent entities must register for a PT program account. We encourage early registration, as filing extensions will not be granted to late registrants.

Question 17: Can a GIR Notification be filed in Canada before the GIR for the same fiscal year is filed in a foreign jurisdiction?

Answer: Yes. Under the Global Minimum Tax Act, there is no requirement to wait until after the filing of the GIR by a qualifying foreign filing entity before filing a GIR Notification in Canada.

Payments

Question 18: Should a PT program account be used for global minimum tax payments, as opposed to the regular business account, for example, – if a taxpayer wanted to make voluntary payments?

Answer: Yes, any payments made for global minimum tax should be made to the PT program account.

Question 19: Can amounts be transferred between a corporate income tax account (RC program account) and a PT program account?

Answer: Yes, it is possible to transfer certain amounts between an RC program account and a PT program account.

Penalties and interest

Question 20: Considering the electronic only filing requirement is being imposed, is the CRA considering penalty and interest relief on late filing due to the complexity?

Answer: Interest relief will be considered on a case-by-case basis. Penalty relief is provided for under the Global Minimum Tax Act. Subsection 98(3) offers penalty relief for the GIR and the GIR Notification for fiscal years that begin before January 1, 2027, and end before July 1, 2028, provided that reasonable measures have been taken to ensure the correct application of the Act.

Question 21: If the CRA has not published guidance on a technical issue, before the Global Minimum Tax Act filing deadline, how should taxpayers determine a reasonable filing position and what records should they keep?

Answer: Taxpayers are still responsible for filing complete and accurate returns based on the Act and applicable Canadian law. Where a provision reasonably supports more than one interpretation, taxpayers should adopt a supportable interpretation that is consistent with the text, context, and purpose of the Act. OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting administrative guidance should be considered as relevant context, to the extent it is consistent with Canadian law.

Where guidance on a technical issue is not available by the filing due date, taxpayers should use best efforts and maintain contemporaneous documentation of the approach and assumptions used.

The CRA recognizes that the global minimum tax rules are new and complex and that guidance may evolve. In administering these rules, including administering penalties, the CRA will consider whether a taxpayer made reasonable efforts in good faith, including appropriate documentation and disclosure.