Global Minimum Tax Act — G-3.3 2
 floor. ( crédit d’impôt transférable commercialisable ) material competitive distortion , in respect of consolidated financial statements, means an application of a specific principle or procedure, under the set of generally accepted accounting principles used in preparing the consolidated financial statements, that results in an aggregate variation greater than €75 million in a fiscal year as compared to the amounts that would have been determined by applying the corresponding IFRS principle or procedure.  ( distorsion importante créant un avantage concurrentiel ) minimum rate means 15%. ( taux minimum ) Minister means the Minister of National Revenue. ( ministre ) minority-owned constituent entity means a constituent entity of an MNE group if the ultimate parent entity of the MNE group holds, directly or indirectly, 30% or less of the ownership interests in the constituent entity. ( entité constitutive à détention minoritaire ) minority-owned parent entity means a particular minority-owned constituent entity that holds, directly or indirectly, the controlling interest in another minority-owned constituent entity unless the controlling interest of the particular minority-owned constituent entity is held, directly or indirectly, by another minority-owned constituent entity. ( entité mère à détention minoritaire ) minority-owned subgroup means (a) a minority-owned parent entity and its minority-owned subsidiaries; or (b) a minority-owned constituent entity that is not a minority-owned parent entity or a minority-owned subsidiary. ( sous-groupe à détention minoritaire ) minority-owned subsidiary means a minority-owned constituent entity the controlling interest in which is held, directly or indirectly, by a minority-owned parent entity. ( filiale à détention minoritaire ) MNE group has the same meaning as in subsection 10 (1). ( groupe d’EMN ) multi-parented MNE group means two or more groups, if (a) the ultimate parent entities of the groups are party to a stapled structure or dual-listed arrangement; and (b) at least one entity or permanent establishment included in any of the groups — or at least one entity, or permanent establishment in respect of a main entity, that would be included in any of the groups if all the ownership interests in that entity or main entity held by group entities of the groups were held by a single group entity of one of the groups — is not located in the jurisdiction in which any other entity or permanent establishment included in any of the groups is located. ( groupe d’EMN à entités mères multiples ) mutual insurance company means a regulated insurance company that does not have share capital and is owned exclusively by its policyholders. ( compagnie d’assurance mutuelle ) negative tax expense constituent entity has the same meaning as in subsection 31 (3). ( entité constitutive avec charge d’impôt négative ) net asset gain , of a constituent entity for a fiscal year, in respect of an election under subsection 18 (23), means the net gain from the disposition of local tangible assets by the constituent entity located in the jurisdiction for which the election was made, excluding the gain or loss on a transfer of assets to another group entity. ( profit net sur cession d’actifs ) net asset loss , of a constituent entity for a fiscal year, in respect of an election under subsection 18 (23), means the net loss from the disposition of local tangible assets by the constituent entity in the fiscal year (excluding the gain or loss on a transfer of assets to another group entity), less the total of all amounts, if any, allocated to the constituent entity under a previous election under that subsection. ( perte nette sur cession d’actifs ) net GloBE income has the same meaning as in subsection 29 (2). ( revenu GloBE net ) net GloBE loss , of an MNE group for a jurisdiction for a fiscal year, means the absolute value of the negative amount, if any, that would be determined, in the absence of section 8 , by