Global Minimum Tax Act — G-3.3 2
respect of the other entities for a fiscal year, is less than the minimum rate; and (c) income of entities located in the particular jurisdiction is not taken into account. ( régime fiscal intégré des sociétés étrangères contrôlées ) consolidated financial statements , of an entity, means (a) if the entity is not the ultimate parent entity of a group described in paragraph 10 (2)(b), the financial statements of the entity prepared in accordance with an acceptable financial accounting standard, in which the assets, liabilities, income, expenses and cash flows of that entity and the entities in which it has a controlling interest are presented as those of a single economic unit; (b) if the entity is the ultimate parent entity of a group described in paragraph 10 (2)(b), the financial statements of the entity that are prepared in accordance with an acceptable financial accounting standard; (c) if the entity has financial statements that would be described in paragraph (a) or (b) except that they are not prepared in accordance with an acceptable financial accounting standard, those financial statements, adjusted to prevent any material competitive distortions; and (d) if the entity does not prepare financial statements described in any of paragraphs (a) to (c), the financial statements — in which the assets, liabilities, income, expenses and cash flows of that entity and other entities are presented as those of a single economic unit — that would have been prepared in accordance with an authorized financial accounting standard that is (i) an acceptable financial accounting standard, or (ii) a financial accounting standard that is adjusted to prevent any material competitive distortions. ( états financiers consolidés ) constituent entity has the same meaning as in subsection 11 (1). ( entité constitutive ) constituent entity-owner means a constituent entity that directly or indirectly holds an ownership interest in another constituent entity of the same MNE group. ( entité détentrice de titres d’une entité constitutive ) controlled foreign company tax regime , of a particular jurisdiction, means a set of tax rules (other than an IIR) under which an entity (referred to in this definition as the “owner”) — that is located in the particular jurisdiction and that holds an ownership interest in another entity (referred to in this definition as the “controlled foreign company”) that is located in another jurisdiction — is subject to current taxation on its share of all or part of the income earned by the controlled foreign company, irrespective of whether that income is distributed on a current basis to the owner. ( régime fiscal des sociétés étrangères contrôlées ) controlling interest means (a) an ownership interest in an entity such that the interest holder (i) is required to consolidate the assets, liabilities, income, expenses and cash flows of the entity on a line-by-line basis in accordance with an acceptable financial accounting standard, or (ii) would have been required to consolidate the assets, liabilities, income, expenses and cash flows of the entity on a line-by-line basis if the interest holder had prepared consolidated financial statements; or (b) the controlling interest that a main entity is deemed to hold in a permanent establishment under paragraph (2)(b). ( participation conférant le contrôle ) cooperative means an entity that (a) collectively markets or acquires goods or services on behalf of its members; and (b) is subject to a tax regime in the jurisdiction in which it is located that is designed to ensure the tax neutrality of the cooperative in respect of the property or services of its members that are sold through the cooperative and property or services that are acquired by members through the cooperative. ( coopérative ) core international shipping activity has the same meaning as in subsection 19 (6). ( activité de transport maritime international principale ) core international shipping costs has the same