GreatNorthCollective/greatnorth-canada-federal-laws-text huggingface dataset:
Global Minimum Tax Act — G-3.3
IIR means a law of a jurisdiction that may reasonably be considered to have been enacted with the intention of implementing, in whole or in part, Articles 2.1 to 2.3 of the GloBE Model Rules. ( RDIR )
Global Minimum Tax Act — G-3.3 (a)
included revaluation method gain or loss , of a constituent entity for a fiscal year, means the net gain or loss, before covered taxes, for the fiscal year in respect of all property, plant and equipment that arises under an accounting method or practice that (a) periodically adjusts the carrying value of such property, plant and equipment to its fair value; (b) records the changes in value in other comprehensive income; and (c) does not subsequently report the gains or losses recorded in other comprehensive income through profit and loss. ( profit ou perte inclus au titre de la méthode de réévaluation )
Global Minimum Tax Act — G-3.3
inclusion ratio has the same meaning as in subsection 15 (3). ( ratio d’inclusion )
Global Minimum Tax Act — G-3.3
Inclusive Framework means the jurisdictions of the OECD and Group of 20 (G20) Inclusive Framework on Base Erosion and Profit Shifting. ( Cadre inclusif )
Global Minimum Tax Act — G-3.3 (a)
insurance investment entity means a particular entity, other than an investment fund or real estate investment vehicle, (a) that would be (i) an investment fund if the definition investment fund in this subsection were read without reference to subparagraph (a)(i) and paragraphs (c) and (d) of that definition, or (ii) a real estate investment vehicle if the definition real estate investment vehicle in this subsection were read without reference to subparagraph (b)(ii) of that definition; (b) that is primarily designed or established to generate investment income or gains to offset, or protect against an event or outcome that gives rise to, liabilities or losses associated with insurance or annuity contracts; and (c) in which each ownership interest is held by one or more entities each of which (i) is a group entity in respect of the particular entity, and (ii) is subject to a regulatory regime, in the jurisdiction in which it is established or managed, that is specific to entities engaged in the business of negotiating and entering into contracts of insurance or annuity or in activities ancillary to that business. ( entité d’investissement d’assurance )
Global Minimum Tax Act — G-3.3
intermediate parent entity means a constituent entity of an MNE group (other than an ultimate parent entity, partially-owned parent entity, permanent establishment, investment entity or insurance investment entity) that holds, directly or indirectly, an ownership interest in another constituent entity of the MNE group. ( entité mère intermédiaire )
Global Minimum Tax Act — G-3.3 (a)
international organization means any intergovernmental or supranational organization, or an entity that acts for, is part of or is wholly owned by that organization, if (a) the organization is comprised primarily of governments; (b) it has in effect a headquarters agreement or substantially similar agreement, such as arrangements for privileges or immunities in respect of its offices or establishments, with the jurisdiction in which it is established; and (c) law or its governing documents prevent its income inuring to the benefit of private persons. ( organisation internationale )
Global Minimum Tax Act — G-3.3
international shipping means the transportation of passengers or cargo by ship in international traffic. ( transport maritime international )
Global Minimum Tax Act — G-3.3
international traffic means any transport by ship, except when the ship is operated solely between places within a single jurisdiction. ( trafic international )
Global Minimum Tax Act — G-3.3
intragroup financing arrangement means any arrangement between two or more group entities of an MNE group under which a high-tax counterparty directly or indirectly provides credit to or otherwise makes an investment in a low-tax entity. ( accord de financement intragroupe )
Global Minimum Tax Act — G-3.3 (a)
investment entity , for a fiscal year, means (a) an entity that is an investment fund for all or substantially all of the fiscal year; (b) an entity that is a real estate investment vehicle for all or substantially all of the fiscal year; (c) a particular entity, if (i) for all or substantially all of the fiscal year ownership interests in the particular entity having a fair market value equal to at least 95% of the fair market value of all ownership interests in the particular entity are held directly, or indirectly through one or more other entities that are investment funds or real estate investment vehicles, by one or more entities that are investment funds or real estate investment vehicles, and (ii) all or substantially all the activities of the particular entity during the fiscal year consist of holding assets or investing funds for the benefit of any of the investment funds or real estate investment vehicles referred to in subparagraph (i); or (d) a particular entity, if (i) for all or substantially all of the fiscal year ownership interests in the particular entity having a fair market value equal to at least 85% of the fair market value of all ownership interests in the particular entity are held directly, or indirectly through one or more other entities that are investment funds or real estate investment vehicles, by one or more entities that are investment funds or real estate investment vehicles, and (ii) all or substantially all the financial accounting income of the particular entity is comprised of excluded dividends or excluded equity gains or losses. ( entité d’investissement )
Global Minimum Tax Act — G-3.3 (a)
investment fund means an entity (a) that is primarily designed or established to (i) pool assets (which may be financial or non-financial) from a number of investors, at least some of which are not connected, and (ii) generate investment income or gains, or protect against a specific or general event or outcome; (b) that invests in accordance with a defined investment policy; (c) that allows investors to reduce transaction, research and analytical costs or to spread risk collectively; (d) the investors in which have a right to the assets of the entity, or income earned on those assets, based on the respective contributions made by those investors; (e) that is, or whose management is, subject to a regulatory regime (which may include appropriate anti-money laundering and investor protection regulations) in the jurisdiction in which the entity is established or managed; and (f) that is managed by investment management professionals on behalf of its investors. ( fonds de placement )
Global Minimum Tax Act — G-3.3 (a)
joint venture , in respect of a particular MNE group (other than a group composed exclusively of excluded entities), means a particular entity (a) whose financial results are reported under the equity method in the consolidated financial statements of the ultimate parent entity of the particular MNE group; (b) of which at least 50% of the ownership interests are held, directly or indirectly, by the ultimate parent entity of the particular MNE group; and (c) that is not (i) the ultimate parent entity of an MNE group, a constituent entity of which, or joint venture in respect of which, is subject to a qualified IIR or qualified UTPR, (ii) an excluded entity described in paragraph 13 (1)(a), (iii) an entity, if (A) all ownership interests in that entity held by group entities in respect of the particular MNE group are held directly by excluded entities described in paragraph 13 (1)(a), and (B) one of the following conditions is met: (I) the entity operates exclusively or almost exclusively to hold assets or invest funds for the benefit of its investors, (II) the entity carries out activities that are ancillary to those carried out by any of those group entities, or (III) all or substantially all of the financial accounting income of the entity is excluded dividends or excluded equity gains, or (iv) a joint venture subsidiary of another joint venture. ( coentreprise )
Global Minimum Tax Act — G-3.3
joint venture entity , of a joint venture group, means the joint venture or a joint venture subsidiary of the group. ( entité d’une coentreprise )
Global Minimum Tax Act — G-3.3
joint venture group means a joint venture and its joint venture subsidiaries, if any. ( groupe d’une coentreprise )
Global Minimum Tax Act — G-3.3
joint venture subsidiary , of a joint venture, means an entity (other than the joint venture or an excluded entity) the assets, liabilities, income, expenses and cash flows of which would, because of ownership or control, be included in the consolidated financial statements of the joint venture if the references to “ultimate parent entity” in the definition consolidated financial statements in this subsection were read as references to the “joint venture”. ( filiale d’une coentreprise )
Global Minimum Tax Act — G-3.3
jurisdictional adjusted covered taxes has the same meaning as in subsection 29 (3). ( impôts concernés ajustés juridictionnels )
Global Minimum Tax Act — G-3.3
jurisdictional excess negative tax expense top-up amount has the same meaning as in subsection 31 (4). ( montant complémentaire de la charge d’impôt négative excédentaire juridictionnel )
Global Minimum Tax Act — G-3.3
jurisdictional GloBE income or loss has the same meaning as in subsection 33 (4). ( résultat net GloBE juridictionnel )
Global Minimum Tax Act — G-3.3
jurisdictional GloBE revenue has the same meaning as in subsection 33 (2). ( chiffre d’affaires GloBE juridictionnel )
Global Minimum Tax Act — G-3.3
jurisdictional top-up amount has the same meaning as in subsection 30 (2). ( montant complémentaire juridictionnel )
Global Minimum Tax Act — G-3.3
local tangible asset , in respect of a constituent entity, means real or immovable property situated in the same jurisdiction as the jurisdiction where the constituent entity is located. ( actif corporel local )
Global Minimum Tax Act — G-3.3
local taxation year of an entity means the period for which the accounts of the entity have been ordinarily made up for the purpose of computing the entity’s income for tax purposes in the jurisdiction in which the entity is located. ( année d’imposition locale )
Global Minimum Tax Act — G-3.3
look-back period , in respect of an election under subsection 18 (23), means the election year and the four fiscal years immediately preceding the election year. ( période antérieure concernée )
Global Minimum Tax Act — G-3.3
loss year , in respect of a jurisdiction for which the filing constituent entity of an MNE group has made an election under subsection 18 (23), means a fiscal year in the look-back period for which a constituent entity of the MNE group that is located in that jurisdiction has a net asset loss and the total amount of net asset losses of all constituent entities of the MNE group that are located in that jurisdiction exceeds the total amount of their net asset gains. ( année de perte )
Global Minimum Tax Act — G-3.3 (a)
low-tax entity means a constituent entity of an MNE group that is located in (a) a low-tax jurisdiction; or (b) a jurisdiction that would be a low-tax jurisdiction if the effective tax rate of the MNE group for the jurisdiction were determined without regard to any income or expense recorded by an entity in respect of an intragroup financing arrangement. ( entité à faible imposition )
Global Minimum Tax Act — G-3.3
low-tax jurisdiction , in respect of an MNE group for a fiscal year, means a jurisdiction where the MNE group has net GloBE income and the effective tax rate of the MNE group for the jurisdiction for that fiscal year is lower than the minimum rate. ( juridiction à faible imposition )
Global Minimum Tax Act — G-3.3
main entity , in respect of a permanent establishment, means the entity that includes the financial accounting income of the permanent establishment in its financial statements. ( entité principale )
Global Minimum Tax Act — G-3.3
marketable price floor , in respect of the transfer of a tax credit, means 80% of the net present value of the tax credit, where the net present value is determined based on the yield to maturity on a debt instrument with equal or similar maturity — limited to a maximum of five-year maturity — issued by the government that granted the tax credit in the same fiscal year as the tax credit is transferred or, if it is not transferred, the origination year. ( prix plancher commercialisable )
Global Minimum Tax Act — G-3.3 (a)
marketable transferable tax credit means all or a portion of a tax credit (other than a qualified refundable tax credit) if (a) in respect of an originator, (i) the tax credit, or portion of the tax credit, is transferable to an unrelated purchaser in the origination year, or within 15 months of the end of the origination year, under the laws of the jurisdiction granting the tax credit, and (ii) one of the following conditions is met: (A) the tax credit, or portion of the tax credit, is transferred to an unrelated purchaser within 15 months of the end of the origination year at a price that equals or exceeds the marketable price floor, or (B) if the tax credit, or portion of the tax credit, is not transferred, or is transferred to a person that is not an unrelated purchaser, similar tax credits are traded between persons and unrelated purchasers within 15 months of the end of the origination year at a price that equals or exceeds the marketable price floor; and (b) in respect of a particular unrelated purchaser, (i) the tax credit, or portion of the tax credit, is transferable from the particular unrelated purchaser to another unrelated purchaser in the fiscal year in which the tax credit, or portion of the tax credit, is purchased by the particular unrelated purchaser under the laws of the jurisdiction granting the tax credit, and (ii) the tax credit, or portion of the tax credit, is acquired by the particular unrelated purchaser at a price that equals or exceeds the marketable price floor. ( crédit d’impôt transférable commercialisable )
Global Minimum Tax Act — G-3.3
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 )
Global Minimum Tax Act — G-3.3
minimum rate means 15%. ( taux minimum )
Global Minimum Tax Act — G-3.3
Minister means the Minister of National Revenue. ( ministre )
Global Minimum Tax Act — G-3.3
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 )
Global Minimum Tax Act — G-3.3
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 )
Global Minimum Tax Act — G-3.3 (a)
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 )
Global Minimum Tax Act — G-3.3
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 )
Global Minimum Tax Act — G-3.3
MNE group has the same meaning as in subsection 10 (1). ( groupe d’EMN )
Global Minimum Tax Act — G-3.3 (a)
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 )
Global Minimum Tax Act — G-3.3
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 )
Global Minimum Tax Act — G-3.3
negative tax expense constituent entity has the same meaning as in subsection 31 (3). ( entité constitutive avec charge d’impôt négative )
Global Minimum Tax Act — G-3.3
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 )
Global Minimum Tax Act — G-3.3
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 )
Global Minimum Tax Act — G-3.3
net GloBE income has the same meaning as in subsection 29 (2). ( revenu GloBE net )
Global Minimum Tax Act — G-3.3
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 the formula A − B where A is the total of all amounts each of which is the GloBE income for the fiscal year of a standard constituent entity of the MNE group that is located in the jurisdiction; and B is the total of all amounts each of which is the GloBE loss for the fiscal year of a standard constituent entity of the MNE group that is located in the jurisdiction. ( perte GloBE nette )
Global Minimum Tax Act — G-3.3
net income or loss from international shipping has the same meaning as in subsection 19 (2). ( résultat net de transport maritime international )
Global Minimum Tax Act — G-3.3 (a)
non-marketable transferable tax credit means all or a portion of a tax credit (other than a qualified refundable tax credit) that (a) in respect of an originator, is not a marketable transferable tax credit but that is transferable in whole or in part; and (b) in respect of a purchaser, is not a marketable transferable tax credit. ( crédit d’impôt transférable non commercialisable )
Global Minimum Tax Act — G-3.3 (a)
non-profit organization means an entity, if (a) the entity is established and operated in the jurisdiction where it is located (i) exclusively for religious, charitable, scientific, artistic, cultural, athletic, educational or other similar purposes, or (ii) as a professional organization, business league, chamber of commerce, labour organization, agricultural or horticultural organization, civic league or an organization operated exclusively for the promotion of social welfare; (b) substantially all of the income of the entity from the activities referred to in paragraph (a) is exempt from income tax in the jurisdiction where the entity is located; (c) the entity has no shareholders or members that have a proprietary or beneficial interest in its income or assets; (d) the income or assets of the entity may not be distributed to, or applied for the benefit of, a private person or non-charitable entity other than (i) pursuant to the conduct of the entity’s charitable activities, (ii) as payment of reasonable compensation for services rendered or for the use of property or capital, or (iii) as payment representing the fair market value of property that the entity has purchased; (e) on termination, liquidation or dissolution of the entity, all of the entity’s assets must be distributed or revert to a non-profit organization or to the government (including any governmental entity) of the jurisdiction where it is located or any political subdivision thereof; and (f) the entity does not carry on a trade or business that is not directly related to the purposes for which it was established. ( organisation à but non lucratif )
Global Minimum Tax Act — G-3.3 (a)
non-qualifying gain or loss means the lesser of (a) the portion of any gain or loss, arising in respect of a transfer of assets and liabilities in connection with a GloBE reorganization, that is subject to income or profits tax in the jurisdiction where the transferor is located; and (b) the portion of the gain or loss that is reflected in the financial accounts. ( profit ou perte non admissible )
Global Minimum Tax Act — G-3.3
OECD means the Organisation for Economic Co-operation and Development. ( OCDE )
Global Minimum Tax Act — G-3.3
OECD Model Tax Convention means the Model Tax Convention on Income and on Capital: Condensed Version 2017 , published by the OECD on December 18, 2017, as amended from time to time. ( Modèle de Convention fiscale de l’OCDE )
Global Minimum Tax Act — G-3.3
origination year means the fiscal year in which the originator of a tax credit satisfies the eligibility criteria for the tax credit under the laws of the jurisdiction granting the tax credit. ( année de création )
Global Minimum Tax Act — G-3.3
originator means the person that engages in the activities that generate a tax credit. ( initiateur )
Global Minimum Tax Act — G-3.3
other comprehensive income , in respect of a constituent entity, means items of income and expense that are recognized outside of the profit or loss account in the financial statements used in determining the entity’s GloBE income or loss. ( autres éléments du résultat global )
Global Minimum Tax Act — G-3.3
owner means an entity that directly or indirectly holds an ownership interest in another entity. ( détenteur )
Global Minimum Tax Act — G-3.3 (a)
ownership interest means an interest that an entity or person holds in a particular entity (a) in the case of a direct interest, that (i) carries rights to the profits, capital or reserves of the particular entity or the particular entity’s permanent establishment, and (ii) would, in the absence of any requirement to consolidate the assets, liabilities, income, expenses and cash flows of the particular entity in the consolidated financial statements, be accounted for as equity in those statements; or (b) in the case of an indirect interest, through a chain of direct ownership interests. ( titre de participation )
Global Minimum Tax Act — G-3.3 (a)
partially-owned parent entity means a constituent entity of an MNE group (other than an ultimate parent entity, permanent establishment, investment entity or insurance investment entity) (a) that holds, directly or indirectly, an ownership interest in another constituent entity of the MNE group; and (b) in which more than 20% of the ownership interests, determined having regard only to the ownership interests that carry rights to profits, are held, directly or indirectly, by persons or entities that are not constituent entities of the MNE group. ( entité mère partiellement détenue )