Global Minimum Tax Act — G-3.3 66
Part 2 — assessment of another constituent entity 66 (1) The Minister may assess a particular constituent entity of an MNE group that is located in Canada in respect of tax and other amounts payable under this Part or Part 2 by another constituent entity of the MNE group that is located in Canada. If such an assessment is made, the particular constituent entity is jointly and severally, or solidarily, liable with the other constituent entity to pay the amount assessed and this Part applies to the particular constituent entity in respect of the amount assessed, with any modifications that the circumstances require. Limitation (2) Subsection (1) does not limit the liability of the other constituent entity under any other provision of this Act or the liability of the particular constituent entity for the interest that the particular constituent entity is liable to pay under this Act on an assessment in respect of the amount that the particular constituent entity is liable to pay because of that subsection. Part 3 — joint and several, or solidary, liability (3) A particular constituent entity that is located in Canada is, in respect of tax and other amounts payable under this Part or Part 3 by another constituent entity of the same MNE group or a joint venture entity in respect of the same MNE group, jointly and severally, or solidarily, liable with the other constituent entity or joint venture entity to pay those amounts and this Part applies to the particular constituent entity in respect of those amounts, with any modifications that the circumstances require. Part 3 — joint and several, or solidary, liability of joint venture entities (4) A particular joint venture entity that is located in Canada is, in respect of tax and other amounts payable under this Part or Part 3 by another joint venture entity of the same joint venture group, jointly and severally, or solidarily, liable with the other joint venture entity to pay those amounts and this Part applies to the particular joint venture entity in respect of those amounts, with any modifications that the circumstances require. Partnerships — joint and several, or solidary, liability (5) A partnership and each member or former member of the partnership (other than a member that is a limited partner and is not a general partner) are jointly and severally, or solidarily, liable for (a) the payment of all amounts that are required to be paid by the partnership under this Act before or during the period during which the member is a member of the partnership and, if the member is a member of the partnership when the partnership is dissolved, after the dissolution of the partnership, except that (i) the member is liable for the payment of amounts that become payable before the period only to the extent of the property that is regarded as property of the partnership under the relevant laws of general application to partnerships in force in a province or other jurisdiction, and (ii) the payment by the partnership or any member of the partnership of an amount in respect of the liability discharges their liability to the extent of that amount; and (b) all other obligations under this Act that arose before or during that period for which the partnership is liable or, if the member was a member of the partnership at the time the partnership was dissolved, the obligations that arose upon or as a consequence of the dissolution. Partnerships — tiers (6) For the purposes of this section, a partnership or other person that is (or is deemed by this subsection to be) a member of a particular partnership that is a member of another partnership is deemed to be a member of the other partnership. Trusts — joint and several, or solidary, liability (7) A trust and all persons that are trustees of that trust at any time during a fiscal year are jointly and severally, or solidarily, liable for the payment of all amounts that are required to be paid by the trust under this Act for the fiscal year. Persons l