Global Minimum Tax Act — G-3.3 2
érative ) core international shipping activity has the same meaning as in subsection 19 (6). ( activité de transport maritime international principale ) core international shipping costs has the same meaning as in subsection 19 (5). ( coûts relatifs au transport maritime international principal ) core international shipping income has the same meaning as in subsection 19 (3). ( revenu de transport maritime international principal ) core international shipping revenue has the same meaning as in subsection 19 (4). ( recettes de transport maritime international principal ) corporation includes an incorporated company, arrangement, association, organization or body. ( société ) covered taxes has the same meaning as in subsection 23 (1). ( impôts concernés ) deductible dividend , in respect of a constituent entity that is subject to a deductible dividend regime, means (a) a distribution of profits, by the constituent entity to the holder of an ownership interest in the constituent entity, that is deductible from income for tax purposes of the constituent entity under the laws of the jurisdiction in which it is located; or (b) a patronage dividend distributed to a member of a cooperative. ( dividende déductible ) deductible dividend regime means a tax regime that (a) is designed to yield a single level of taxation, on the owners of an entity, through a deduction from the income of the entity for distributions of profits to the owners (which, for this purpose, are considered to include patronage dividends); or (b) is applicable to cooperatives and exempts the cooperative from taxation. ( régime des dividendes déductibles ) deemed distribution tax has the same meaning as in subsection 37 (2). ( impôt sur les distributions présumées ) deemed distribution tax recapture account means an account established and maintained in accordance with subsection 37 (1). ( compte de récupération de l’impôt sur les distributions présumées ) departing constituent entity , of an MNE group, means an entity that is a standard constituent entity of the MNE group located in a jurisdiction in a fiscal year in respect of which an election is made under subsection 37 (1) and that has subsequently (a) left the MNE group; or (b) transferred substantially all of its assets to a recipient that is not, at the time of the transfer, a standard constituent entity of the MNE group located in the jurisdiction. ( entité constitutive sortante ) disallowed accrual , of a constituent entity, means any movement in deferred tax expense recorded in the constituent entity’s financial accounts that relates to (a) an uncertain tax position; or (b) a distribution from a group entity in respect of the constituent entity. ( accumulation non admise ) disposition recapture ratio has the same meaning as in subsection 37 (6). ( ratio de récupération de disposition ) disqualified refundable imputation tax means an amount of tax paid or accrued by a constituent entity (other than an amount of tax paid or accrued that is a qualified imputation tax) that is (a) refundable to the beneficial owner of a dividend or similar distribution by the constituent entity; (b) creditable against a tax liability (other than a tax liability in respect of the distribution) of the beneficial owner; or (c) refundable to, or creditable against a tax liability of, the constituent entity, in respect of the distribution. ( impôt d’imputation remboursable non admissible ) domestic top-up amount has the same meaning as in subsection 52 (1). ( montant complémentaire national ) dual-listed arrangement means an arrangement entered into by the ultimate parent entities of two or more groups, under which (a) all or substantially all the businesses of the groups are combined by contract alone; (b) pursuant to contractual arrangements, the ultimate parent entities each make distributions (including dividends and distributions on a liquidation, if relevant) to their respective owners on the basis of a fixed ratio; (c) the a