- acceptable financial accounting standard
s Republic of China),(vi)Japan,(vii)Mexico,(viii)New Zealand,(ix)People’s Republic of China,(x)Republic of India,(xi)Republic of Korea,(xii)Singapore,(xiii)Switzerland,(xiv)United Kingdom, or(xv)United States. (norme de comptabilité financière admissible)
- action
- adjusted covered taxes
- adjusted investment amount
), means the amount determined by the formulaA − B − CwhereAis the investment amount of the owner in respect of the ownership interest;Bis the total of all amounts each of which is the qualified flow-through tax benefits of the owner in respect of the ownership interest for a fiscal year preceding the determination year; andCis the total of all amounts each of which is the other flow-through amounts of the owner in respect of the ownership interest for the determination year or any preceding fiscal year. (montant d’investissement ajusté)
- adjustment year
ajustement)
- Agency
- aggregate asset gain
actifs)
- aggregate asset loss
actifs)
- allocable share
- allocated adjustment top-up amount
ajustement attribué)
- ancillary international shipping activity
- ancillary international shipping costs
- ancillary international shipping income
- ancillary international shipping revenue
- assessment
- authorized financial accounting standard
- authorized person
- bank
- bankrupt
- blended controlled foreign company tax regime
- business number
entreprise)
- Canadian filing entity
- Commissioner
- confidential information
- consolidated financial statements
- constituent entity
- constituent entity-owner
une entité constitutive)
- controlled foreign company tax regime
) — 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)
- controlling interest
- cooperative
- core international shipping activity
- core international shipping costs
- core international shipping income
- core international shipping revenue
- corporation
- court of appeal
appel)
- covered taxes
- deductible dividend
- deductible dividend regime
- deduction/non-inclusion arrangement
- deemed distribution tax
- deemed distribution tax recapture account
impôt sur les distributions présumées)
- departing constituent entity
- designated filing entity
- designated local entity
- designated notification entity
- disallowed accrual
s financial accounts that relates to(a)an uncertain tax position; or(b)a distribution from a group entity in respect of the constituent entity. (accumulation non admise)
- disposition recapture ratio
- disqualified refundable imputation tax
imputation remboursable non admissible)
- domestic top-up amount
- dual-listed arrangement
entities are presented together as those of a single economic unit and those financial statements(i)would be
- duplicate loss arrangement
- duplicate tax recognition arrangement
- effective tax rate
imposition)
- eligible distribution tax system
impôt sur les distributions)
- eligible employee
- eligible payroll costs
- eligible tangible asset
- eligible tangible asset amount
actif corporel admissible)
- entity
- ETR adjustment provision
ajustement du TEI)
- excess benefits
s current tax expense in respect of covered taxes in its financial accounts can reasonably
- excess negative tax expense
impôt négative excédentaire)
- excess negative tax expense top-up amount
impôt négative excédentaire)
- excess profit
- excluded costs
- excluded dividends
- excluded entity
- excluded equity gain or loss
- excluded taxes
- expected tax benefits ratio
- filing constituent entity
- financial accounting income
- financial accounting revenue
affaires comptable)
- fiscal year
- fiscally transparent
s interest in the entity. (fiscalement transparent)
- five-year election
- flow-through entity
- flow-through tax benefits
- general government
- GIR
- GIR due date
échéance DRG)
- GIR exchange date
échange DRG)
- GloBE Commentary
- GloBE income
s GloBE income or loss for the fiscal year. (revenu GloBE)
- GloBE income or loss
- GloBE loss
s GloBE income or loss for the fiscal year. (perte GloBE)
- GloBE Model Rules
- GloBE reorganization
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(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 transferr
- GloBE transition year
- governmental entity
s assets through the making and holding of investments, asset management and related investment activities for the government’s assets;(c)it does not carry on a trade or business;(d)it is accountable to the government on its overall performance and provides annual information reporting to the government;(e)its assets vest in the government upon dissolution; and(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)
- group
- group entity
- high-tax counterparty
- hybrid entity
- IFRS
- IIR
- included revaluation method gain or loss
- inclusion ratio
inclusion)
- Inclusive Framework
- initial phase of international activity year
- insurance investment entity
investissement d’assurance)
- intermediate parent entity
- international organization
- international shipping
- international traffic
- intragroup financing arrangement
- investment amount
investissement)
- investment entity
- investment entity adjusted covered taxes amount
entité d’investissement)
- investment entity GloBE income amount
entité d’investissement)
- investment fund
- investment subgroup
investissement)
- investment subgroup entity
investissement)
- joint venture
- joint venture entity
une coentreprise)
- joint venture group
une coentreprise)
- joint venture subsidiary
in the definition consolidated financial statements in this subsection were read as references to the “joint venture”. (filiale d’une coentreprise)
- judge
- jurisdictional adjusted covered taxes
- jurisdictional excess negative tax expense top-up amount
impôt négative excédentaire juridictionnel)
- jurisdictional GloBE income or loss
- jurisdictional GloBE revenue
affaires GloBE juridictionnel)
- jurisdictional top-up amount
- legal representative
s estate or succession. (représentant légal)
- local tangible asset
- local taxation year
s income for tax purposes in the jurisdiction in which the entity is located. (année d’imposition locale)
- look-back period
- loss year
- low-tax entity
- low-tax jurisdiction
- main entity
- marketable price floor
- marketable transferable tax credit
- material competitive distortion
- minimum rate
- Minister
- minority investor percentage
investisseur minoritaire)
- minority-owned constituent entity
- minority-owned investment entity
investissement à détention minoritaire)
- minority-owned investment subgroup
investissement à détention minoritaire)
- minority-owned parent entity
- minority-owned subgroup
- minority-owned subsidiary
- MNE group
EMN)
- multi-parented MNE group
EMN à entités mères multiples)
- mutual insurance company
assurance mutuelle)
- negative tax expense constituent entity
impôt négative)
- net asset gain
actifs)
- net asset loss
actifs)
- net book value
- net GloBE income
- net GloBE loss
- net income or loss from international shipping
- net unrealized fair value loss
- non-marketable transferable tax credit
impôt transférable non commercialisable)
- non-material constituent entity
s assets, liabilities, income, expenses and cash flows are not included in the ultimate parent entity’s consolidated financial statements;(b)the consolidated financial statements are(i)described in paragraph (a) or (c) of the definition consolidated financial statements in subsection 2(1), and(ii)externally audited and the accompanying auditor’s opinion does not contain objections or qualifications in relation to the exclusion of the particular constituent entity from the consolidation perimeter; and(c)where the total revenue, as reported on the MNE group’s country-by-country report, that is attributable to the particular constituent entity for a fiscal year is greater than €50 million, the financial accounts that are used to complete the MNE group’s country-by-country report are prepared in accordance with an acceptable financial accounting standard or authorized financial accounting standard. (entité constitutive non matérielle)
- non-profit organization
s charitable activities,(ii)as payment of reasonable compensation for services rendered or for the use of property or capital, or(iii)as payment representing the fair market value of property that the entity has purchased;(e)on termination, liqui
- non-qualifying gain or loss
- OECD
- OECD Model Tax Convention
OCDE)
- official
- origination year
- originator
- other comprehensive income
s GloBE income or loss. (autres éléments du résultat global)
- other flow-through amounts
- owner
- ownership interest
s permanent establishment, and(ii)would, in the absence of any requirement to consolidate the assets, liabilities, income, expenses and cash flows of the particular entity in the consolidated financial statements, be accounted for as equity in those statements; or(b)in the case of an indirect interest, through a chain of direct ownership interests. (titre de participation)
- partially-owned parent entity
- passive income
s GloBE income or loss and that is(a)a dividend or dividend equivalent;(b)interest or an interest equivalent;(c)rent;(d)a royalty;(e)an annuity; or(f)a net gain from property of a type that produces income described in any of paragraphs (a) to (e). (revenu passif)
- patronage dividend
- pension fund
- pension services entity
- permanent establishment
- person
- planning activity
- portfolio holding
- prescribed
- profit (loss) before income tax
s qualified country-by-country report (or that would have been so reported if the MNE group had been required to file a country-by-country report), that is attributable to standard constituent entities, adjusted to (a)exclude any net unrealized fair value loss in the jurisdiction that exceeds €50 million; and(b)add back any amount recorded as a reduction in income in the financial accounts of a standard constituent entity that is attributable to an impairment of goodwill related to any transaction entered into after November 30, 2021, for the purposes of applying(i)the routine profits test under subsection (6), and(ii)the simplified effective tax rate test under subsection (4), if the financial accounts of the standard constituent entity do not also have a reversal of a deferred tax liability, or recognition or increase of a deferred tax asset, in respect of the impairment of goodwill. (bénéfice (perte) avant impôts)
- proportional amortization method interest
amortissement proportionnelle)
- proportional amortization method investment remaining amount
), means the amount determined by the formulaA − BwhereAis the investment amount of the owner in respect of the interest; andBis the total of all amounts each of which is the lesser of the following amounts for the determination year or a preceding fiscal year:(a)the amount determined by the formulaC + DwhereCis(i)in the case of the determination year, nil, and(ii)in any other case, the qualified flow-through tax benefits of the owner in respect of the interest for the fiscal year, andDis the other flow-through amounts of the owner in respect of the interest for the fiscal year, and(b)the proportional investment reduction amount of the owner in respect of the interest for the fiscal year. (montant de l’investissement résiduel selon la méthode d’amortissement proportionnelle)
- proportional investment reduction amount
investissement proportionnel)
- QDMTT transition year
- qualified ancillary international shipping income
- qualified country-by-country report
- qualified debt release amount
),(ii)it is reasonable to consider that, in the absence of the release of debts owed to one or more third-party creditors under the arrangement, the debtor would be insolvent within 12 months of the date of the release, and(iii)the debtor provides an independent expert opinion attesting that the condition in subparagraph (ii) is met; or(c)if neither paragraph (a) nor (b) applies,(i)the amount is in respect of a debt owed to a third-party creditor,(ii)the debtor’s liabilities exceed the fair market value of its assets, determined immediately before the debt r
- qualified domestic minimum top-up tax
s website. (impôt complémentaire minimum national admissible)
- qualified financial statements
s country-by-country report, or(iv)if a standard constituent entity is a permanent establishment that does not have separate financial accounts described in subparagraph (i) or separate financial statements described in subparagraph (ii), the separate financial statem
- qualified flow-through ownership interest
- qualified flow-through tax benefits
- qualified IIR
s website. (RDIR admissible)
- qualified imputation tax
); and(b)refundable to, or creditable against the tax liability of, the beneficial owner of a dividend or similar distribution by the constituent entity (or by the main entity in respect of the constituent entity, if the constituent entity is a permanent establishment), if(i)the amount is refundable or creditable under(A)subsection 126(1) or (2) of the Income Tax Act, or(B)a provision of the laws of another jurisdiction that is substantially similar to one of those subsections, or(ii)the beneficial owner is(A)subject to tax on a current basis, in respect of the dividend or similar distribution, under the laws of the subject jurisdiction at a nominal rate that is greater than or equal to the minimum rate,(B)an individual who is(I)resident for income tax purposes in the subject jurisdiction, and(II)subject to tax, in respect of the dividend or similar distribution as ordinary income, under the laws of the subject jurisdiction,(C)a governmental entity or international organiza
- qualified person
- qualified refundable tax credit
impôt remboursable admissible)
- qualified substance-based income exclusion amount
s qualified country-by-country report(a)is not regarded as a constituent entity of the MNE group; or(b)is not regarded as located in the jurisdiction. (montant de l’exclusion de revenus fondée sur la substance admissible)
- qualified UTPR
s website. (RPII admissible)
- qualifying competent authority agreement
- qualifying foreign filing entity
) other than Canada in the fiscal year;(c)the constituent entity is obligated to file a GIR, in respect of the MNE group for the fiscal year, with the tax authority of the filing jurisdiction; and(d)the filing jurisdiction has a qualifying competent authority agreement that is in effect, and to which Canada is a party, on or before the GIR exchange date for the fiscal year. (entité déclarante étrangère admissible)
- qualifying income tax expense
impôts admissibles)
- qualifying MNE group
EMN admissible)