Canada Proposes Global Minimum Tax Changes, Including US Exemption

Canada’s government introduced legislation Thursday to apply the so-called side-by-side deal struck at the OECD that exempts US companies from parts of the global minimum tax framework.

The legislation proposes two framework safe harbors—the side-by-side safe harbor and the ultimate parent entity safe harbor. It also proposes an undertaxed profits rule, or UTPR, a backstop measure if an existing global minimum tax rule doesn’t ensure that companies pay the 15% minimum rate.

• The UTPR would allow Canada to impose a top-up tax on a multinational company with subsidiaries in its jurisdiction to make up for any low-taxed profits in the ...