Global Minimum Tax Act — G-3.3 2
 cinq ans ) flow-through entity means an entity to the extent it (a) is fiscally transparent under the laws of the jurisdiction where it was created; and (b) is not subject to a covered tax on its income or profit in another jurisdiction as a result of being tax resident in that jurisdiction. ( entité intermédiaire ) flow-through tax benefits has the same meaning as in subsection 28 (1). ( avantages fiscaux intermédiaires ) general government means the central administration, agencies whose operations are under its effective control, state and local governments and their respective administrations. ( administration publique ) GIR means an information return that contains the information, and is disseminated, in accordance with the Tax Challenges Arising from the Digitalisation of the Economy — GloBE Information Return (Pillar Two) published by the OECD on July 13, 2023, as amended from time to time, and that is (a) if required to be filed with the Minister by a constituent entity located in Canada under subsection 60 (1) or 60 (2) or subparagraph 60 (3)(b)(i), the information return in prescribed form; and (b) in any other case, a substantially similar information return that is required to be filed in a jurisdiction other than Canada. ( DRG ) GloBE Commentary means the commentary entitled Tax Challenges Arising from the Digitalisation of the Economy — Commentary to the Global Anti-Base Erosion Model Rules (Pillar Two) , published by the OECD on March 14, 2022, as amended from time to time. ( commentaires GloBE ) GloBE income , of a constituent entity for a fiscal year, means the positive amount, if any, of the constituent entity’s GloBE income or loss for the fiscal year. ( revenu GloBE ) GloBE income or loss has the meaning assigned in section 16 . ( résultat net GloBE ) GloBE loss , of a constituent entity for a fiscal year, means the absolute value of the negative amount, if any, of the constituent entity’s GloBE income or loss for the fiscal year. ( perte GloBE ) GloBE Model Rules means the model rules set out in the document entitled Tax Challenges Arising from the Digitalisation of the Economy — Global Anti-Base Erosion Model Rules (Pillar Two) published by the OECD on December 20, 2021. ( règles GloBE ) GloBE reorganization means a transformation or transfer of assets and liabilities such as in a merger, demerger, liquidation or similar transaction, if (a) it is the case that (i) if no consideration is provided for the transfer, the issuance of an equity interest as consideration for the transfer would have no economic significance because the transaction does not result in a change in the beneficial ownership of an entity, and (ii) in any other case, the consideration for the transfer consists, in whole or in significant part, of (A) if the transaction is a liquidation, the cancellation of equity interests of the entity that is the subject of the liquidation, and (B) in any other case, equity interests issued by the transferee or an entity that is connected with the transferee; (b) the transferor’s gain or loss on the transfer is not subject, in whole or in part, to an income or profits tax in any jurisdiction; and (c) for the purpose of determining the transferee’s income or profits that are subject to an income or profits tax of the jurisdiction in which it is located, the transferee is required under the laws of that jurisdiction to use the transferor’s tax basis in respect of the transferred assets, adjusted to reflect any non-qualifying gain or loss in respect of the transfer. ( réorganisation GloBE ) GloBE transition year , of an MNE group in respect of a jurisdiction, means the first fiscal year in which (a) a constituent entity of, or joint venture entity in respect of, the MNE group that is located in the jurisdiction is subject to a qualified IIR or qualified UTPR; and (b) subsection 33 (1) or 47 (2), section 45 or an equivalent provision under another qualified IIR or qualified UTPR does not apply for the j