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Osgoode Hall Law School of York University

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2023

Global Minimum Tax

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Full-Text Articles in Law

Introducing A Global Minimum Tax (Pillar Two) In Canada: Some Knowns And Unknowns, Jinyan Li Jan 2023

Introducing A Global Minimum Tax (Pillar Two) In Canada: Some Knowns And Unknowns, Jinyan Li

Articles & Book Chapters

This paper provides a high-level overview of Pillar Two Global Minimum Tax in terms of its policy objectives, technical design and implications for Canada. After teasing out some significant known and unknown challenges, it offers some thoughts on whether, and if so, how and when Canada can proceed with implementation.


Canadian Qdmtt Challenges, Jinyan Li, Angelo Nikolakakis, Jean-Pierre Vidal Jan 2023

Canadian Qdmtt Challenges, Jinyan Li, Angelo Nikolakakis, Jean-Pierre Vidal

Articles & Book Chapters

Nobody believes that Canada is a tax haven. The fact remains that the effective tax rate of certain entities could be less than 15%. If nothing is done, Pillar Two could therefore apply and taxes that naturally accrue to Canada could end up in foreign hands. We must therefore find a solution and the most obvious is that of adopting a qualified domestic minimum top up tax. Other solutions are possible, but they seem less attractive. A QDMTT still presents some challenges. These challenges include sharing with the provinces, determining the priority to be given to certain foreign taxes relating …