Global Minimum Tax Act — G-3.3 2
ction 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 jurisdiction. ( année de transition GloBE ) governmental entity means an entity, if (a) it is part of or wholly owned by a government (including any political subdivision or local authority of the government); (b) its principal purpose is (i) to fulfill a government function, or (ii) to manage or invest the government’s assets through the making and holding of investments, asset management and related investment activities for the government’s assets; (c) it does not carry on a trade or business; (d) it is accountable to the government on its overall performance and provides annual information reporting to the government; (e) its assets vest in the government upon dissolution; and (f) if it distributes net earnings, the net earnings are distributed solely to the government with no portion of its net earnings inuring to the benefit of any private person. ( entité gouvernementale ) group has the same meaning as in subsection 10 (2). ( groupe ) group entity , in respect of another entity or a group, means an entity that is a member of the same group. ( entité du groupe ) high-tax counterparty means a constituent entity of an MNE group that is located in a jurisdiction that (a) is not a low-tax jurisdiction; or (b) would not 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. ( contrepartie à imposition élevée ) hybrid entity , in relation to an owner, means an entity that is (a) not fiscally transparent in the jurisdiction where it is located; and (b) fiscally transparent in the jurisdiction where the owner is located. ( entité hybride ) IFRS means International Financial Reporting Standards. ( IFRS ) 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 ) 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 ) inclusion ratio has the same meaning as in subsection 15 (3). ( ratio d’inclusion ) Inclusive Framework means the jurisdictions of the OECD and Group of 20 (G20) Inclusive Framework on Base Erosion and Profit Shifting. ( Cadre inclusif ) 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