The proposed Global Minimum Tax Act (“GMT Act”) introduces a new form of taxation applicable to Canadian taxpayers that belong to “qualifying MNE groups” starting (in most cases) with 2024 taxation years. In principle, this tax is meant to apply to earnings otherwise taxed at a rate of less than 15%. However, under certain circumstances the earnings of Canadian entities, and as well as the earnings of their subsidiaries in other high tax rate jurisdictions, could be subject to top-up tax under these rules. The presenters will review certain aspects of the GMT Act, with a focus on practical examples that identify tips and traps for those trying to navigate the rules.
