Canadian QDMTT Challenges

Abstract

Nobody believes that Canada is a tax haven. The fact remains that the effective tax rate of certain entities could be less than 15 percent. 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 (QDMTT). 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 to Canadian income (that is, whether those foreign taxes take priority over the QDMTT or vice versa), and estimating certain foreign taxes.