Global Minimum Tax Act — G-3.3 2
uction in the debtor’s deferred tax assets resulting from the debt release, and (C) the amount included, as a result of the debt release, in computing net income or loss. ( montant de la libération de la dette admissible ) qualified domestic minimum top-up tax , for a fiscal year, means a law of a jurisdiction that has the status of a qualified domestic minimum top-up tax (including transitional qualified status) for the fiscal year as determined by the Inclusive Framework and published on the OECD’s website. ( impôt complémentaire minimum national admissible ) qualified flow-through ownership interest has the same meaning as in subsection 28 (1). ( titre de participation intermédiaire admissible ) qualified IIR , for a fiscal year, means an IIR that has qualified status (including transitional qualified status) for the fiscal year as determined by the Inclusive Framework and published on the OECD’s website. ( RDIR admissible ) qualified imputation tax means an amount of covered taxes, paid or accrued by a constituent entity, that is (a) imposed under the laws of a jurisdiction (referred to in this definition as the “subject jurisdiction”); and (b) refundable to, or creditable against the tax liability of, the beneficial owner of a dividend or similar distribution by the constituent entity (or by the main entity in respect of the constituent entity, if the constituent entity is a permanent establishment), if (i) the amount is refundable or creditable under (A) subsection 126(1) or (2) of the Income Tax Act , or (B) a provision of the laws of another jurisdiction that is substantially similar to one of those subsections, or (ii) the beneficial owner is (A) subject to tax on a current basis, in respect of the dividend or similar distribution, under the laws of the subject jurisdiction at a nominal rate that is greater than or equal to the minimum rate, (B) an individual who is (I) resident for income tax purposes in the subject jurisdiction, and (II) subject to tax, in respect of the dividend or similar distribution as ordinary income, under the laws of the subject jurisdiction, (C) a governmental entity or international organization, (D) an investment entity (other than a group entity in respect of the constituent entity) that is created and regulated in the subject jurisdiction, (E) a non-profit organization or pension fund that is created and managed in the subject jurisdiction, or (F) a life insurance company that is located in the subject jurisdiction to the extent that the dividend or similar distribution is (I) received in connection with a business that is substantially similar to that of a pension fund, and (II) subject to tax, under the laws of the subject jurisdiction, in a manner that is substantially similar to the manner in which a pension fund is, under the laws of the subject jurisdiction, subject to tax in respect of a dividend or similar distribution. ( impôt d’imputation admissible ) qualified refundable tax credit means a refundable tax credit (other than any amount of tax creditable or refundable pursuant to a qualified imputation tax or a disqualified refundable imputation tax) to the extent that it is designed to be payable or available as cash or cash equivalents within four years from when a constituent entity satisfies the conditions for receiving the credit under the laws of the jurisdiction granting the credit. ( crédit d’impôt remboursable admissible ) qualified UTPR , for a fiscal year, means a UTPR that has qualified status (including transitional qualified status) for the fiscal year as determined by the Inclusive Framework and published on the OECD’s website. ( RPII admissible ) qualifying MNE group has the same meaning as in subsection 9 (1). ( groupe d’EMN admissible ) qualifying non-profit subsidiary , for a fiscal year, means an entity in respect of an MNE group if (a) the entity is wholly owned by one or more entities that are non-profit organizations; and (b) the revenue of the MNE group fo