TEI Comments on the Proposed Implementation of Pillar Two (Global Minimum Tax) in Canada

On July 21, 2022, TEI submitted preliminary comments to the Department of Finance concerning the Government of Canada’s proposal to implement Pillar Two of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (“BEPS”) two-pillar plan for international tax reform, as contemplated by the federal budget documents tabled in Canada’s House of Commons on April 7, 2022 (“Budget 2022”).  TEI’s comments highlight several areas of significant, widespread concern with the plan’s implementation in Canada, as contemplated by Budget 2022, that warrant further and careful attention.

TEI’s comments were developed jointly by a working group of concerned members under the aegis of TEI’s Canadian Income Tax Committee, whose Chair is Patricia Likogiannis.  Principal responsibility for drafting TEI’s comments was exercised by Watson M. McLeish, TEI Tax Counsel.