Global Minimum Tax Act — G-3.3 2
ngements, 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 activities of the groups are managed as those of a single economic unit; (d) the groups retain the separate legal identity they had before the arrangement was entered into; (e) ownership interests of at least one of the ultimate parent entities are quoted, traded or transferred independently on a securities market that is not the same as the securities market on which the ownership interests of another of the ultimate parent entities are quoted, traded or transferred independently; and (f) financial statements are prepared by one or more of the ultimate parent entities in which the assets, liabilities, income, expenses and cash flows of the groups’ entities are presented together as those of a single economic unit and those financial statements (i) would be consolidated financial statements if the groups’ entities were included in a single group and the ultimate parent entity that prepared the financial statements were the ultimate parent entity of that group, and (ii) are required by an applicable regulatory regime of a jurisdiction to be externally audited. ( accord de double cotation ) effective tax rate has the same meaning as in subsection 29 (1). ( taux effectif d’imposition ) eligible distribution tax system , of a jurisdiction, means a corporate income tax system that is applicable in the jurisdiction that (a) generally imposes tax on the profits, or certain non-business expenses, of a corporation only when the corporation (i) distributes those profits to its shareholders, (ii) is deemed to distribute those profits to its shareholders, or (iii) incurs those expenses; (b) imposes tax at a rate greater than or equal to the minimum rate; and (c) was in force on or before July 1, 2021. ( régime admissible d’impôt sur les distributions ) eligible employee has the same meaning as in subsection 32 (8). ( employé admissible ) eligible payroll costs has the same meaning as in subsection 32 (2). ( frais de personnel admissibles ) eligible tangible asset has the same meaning as in subsection 32 (14). ( actif corporel admissible ) eligible tangible asset amount has the same meaning as in subsection 32 (9). ( montant de l’actif corporel admissible ) entity means a corporation, a partnership, a trust or any other arrangement, association, organization or body whether registered or unregistered for which separate financial accounts are prepared, but does not include a central, state or local government or its administration or agencies that carries out government functions. ( entité ) ETR adjustment provision means paragraph 18 (23)(c), subsection 25 (6), paragraph 27 (1)(b), subsection 27 (4) or paragraph 37 (4)(b) or (5)(b). ( disposition d’ajustement du TEI ) excess negative tax expense has the same meaning as in subsection 29 (4). ( charge d’impôt négative excédentaire ) excess negative tax expense top-up amount has the same meaning as in subsection 31 (2). ( montant complémentaire de la charge d’impôt négative excédentaire ) excess profit has the same meaning as in subsection 30 (4). ( bénéfice excédentaire ) excluded costs has the same meaning as in subsection 32 (3). ( coûts exclus ) excluded dividends means dividends or other distributions received or accrued by a constituent entity in respect of an ownership interest in an entity, other than (a) a dividend or other distribution received or accrued in respect of (i) an interest that is a short-term portfolio holding of the constituent entity on the earlier of (A) the date of the distribution, and (B) the date on which the constituent entity becomes entitled to the distribution, or (ii) an ownership interest in an investment entity that is subject to an election under subsection 42 (2); or (b) a dividend or other distribution received or accrued (i) to the extent that it can reason