Tax Planning
How Canada’s Global Minimum Tax Affects Multinationals in 2026
If you're part of a multinational enterprise with €750 million+ in revenue, new rules under Canada’s Global Minimum Tax Act mean you’ll need to understand top-up tax obligations, filing requirements, and recent legislative updates to avoid penalties.
By NomadicTax Research Team • 6 min read • May 28, 2026
## What the Global Minimum Tax Is
The Global Minimum Tax Act (GMTA), which received royal assent in **June 2024**, implements Pillar Two of the OECD’s two-pillar framework. It ensures that large multinational enterprise (MNE) groups — typically with consolidated annual revenue ≥ **€750 million** — pay a minimum **15% effective tax rate** in every jurisdiction where they operate.([canada.ca](https://www.canada.ca/en/services/taxes/excise-taxes-duties-and-levies/global-minimum-tax.html?utm_source=openai)) If your entity qualifies, you’ll face two categories of tax: the **Income Inclusion Rule (IIR)** (global top-up on profits taxed below 15%) and the **Domestic Minimum Top-Up Tax** for entities located in Canada.([canada.ca](https://www.canada.ca/en/services/taxes/excise-taxes-duties-and-levies/global-minimum-tax.html?utm_source=openai))
## Key Filing and Registration Requirements
If you’re subject to GMTA, Canadian entities must:
- Register for a **PT program account** with the CRA. This is needed if you have tax liability under Part 2 (IIR) or Part 3 (domestic top-up), or must file prescribed returns.([canada.ca](https://www.canada.ca/en/services/taxes/excise-taxes-duties-and-levies/global-minimum-tax/register-account.html?utm_source=openai))
- File the **GloBE Information Return (GIR)** and any Global Minimum Tax Return or notification, depending on your group’s activities.([canada.ca](https://www.canada.ca/en/services/taxes/excise-taxes-duties-and-levies/global-minimum-tax/get-ready-file.html?utm_source=openai))
- Maintain records for **at least eight years** to support compliance.([canada.ca](https://www.canada.ca/en/services/taxes/excise-taxes-duties-and-levies/global-minimum-tax/get-ready-file.html?utm_source=openai))
Filing due dates: for fiscal years beginning **on or after December 31, 2023**, returns or notifications are generally due **15-18 months** after the fiscal year ends.([canada.ca](https://www.canada.ca/en/services/taxes/excise-taxes-duties-and-levies/global-minimum-tax/get-ready-file.html?utm_source=openai))
## Recent Legislative Proposals You Should Know
In **May 2026**, Bill C-31 (Budget 2025 Implementation Act No. 2) introduced amendments to:
- **Preserve the integrity** of the Global Minimum Tax Act to ensure corporations pay the minimum in all jurisdictions.([canada.ca](https://www.canada.ca/en/department-finance/news/2026/05/minister-champagne-introduces-second-piece-of-legislation-to-implement-budget-2025-canada-strong.html?utm_source=openai))
- Include a definition of **“private investment entity”** under the GMTA, to address situations where private corporations control publicly listed companies.([fin.canada.ca](https://fin.canada.ca/drleg-apl/2026/ita-lir-0126-l-1-eng.html?utm_source=openai))
These will affect how top-up tax is calculated, which entity makes the filing, and how definitions of ownership or corporate structure are interpreted.
## Practical Examples
| Scenario | Tip | Why It Matters |
|---|---|---|
| A Canadian subsidiary of a €1B MNE group with offices in low-tax country | Calculate IIR liability: determine whether profits taxed abroad under IIR are below 15%, compute top-up payable in Canada. | To avoid underreporting and penalties. |
| A private Canadian entity controlling a listed company abroad | Review new definition of “private investment entity” to see whether special treatment applies under Bill C-31. | Determines whether top-up tax or reporting is altered. |
| Multiple constituent entities in group | Determine which filling constituent entity will lodge the return/notification, maintain BN (business number), coordinate all entities. | To meet CRA registration and filing duties correctly. |
## Actionable Tips to Stay Compliant
- Start by **mapping your group’s global presence**: list all jurisdictions, tax rates, and revenue thresholds.
- Update transfer pricing policies and **review foreign income** taxed at low rates.
- Register for the CRA’s **program account early**, if you have obligations. Don’t wait for notification.
- Keep detailed global financials, staging for foreign jurisdictions and related party transactions.
- Consult with tax advisers before implementing corporate restructuring, especially if you’re in sectors like financial services or private equity.
Understanding GMTA and its associated legislative changes in 2026 is critical for any qualifying multinational. With updated definitions and risks increasing for non-compliance, early action can save you from surprises when filing and paying top-up taxes.