The Global Minimum Tax Act (“GMTA”) was enacted in Canada in 2024 and applies to qualifying multinational enterprise (“MNE”) groups for fiscal years that begin on or after December 31, 2023. It imposes filing requirements (i.e. the Global Minimum Tax Return) and a minimum tax (i.e. minimum effective tax rate of 15% to profits of the MNE group). A qualifying MNE group for a particular fiscal year is an MNE group with €750 million or more in revenue reported in the consolidated financial statements of its ultimate parent entity (in at least 2 of the 4 fiscal years immediately preceding the particular fiscal year) and that is not composed exclusively of excluded entities for the particular fiscal year.
A Canadian member of a qualifying MNE group needs to register for a PT program account before filing the Global Minimum Tax Return with CRA. Registration for the PT program opened as of 25 October 2025. If you think you meet the qualifying MNE group definition or have questions about the GMT, please contact your Rolfe Benson partner.
