Global Minimum Tax Act — G-3.3 47
e test under subsection (4), if the financial accounts of the standard constituent entity do not also have a reversal of a deferred tax liability, or recognition or increase of a deferred tax asset, in respect of the impairment of goodwill. ( bénéfice (perte) avant impôts ) qualified country-by-country report , in respect of an MNE group, means a country-by-country report for a jurisdiction for a fiscal year that (a) is filed in accordance with the relevant country-by-country reporting regulations (as defined in section 43 ); (b) is prepared on the basis of qualified financial statements of the standard constituent entities of the MNE group for the jurisdiction for the fiscal year; and (c) in the case of a multi-parented MNE group, includes the information of all constituent entities of the multi-parented MNE group. ( déclaration pays par pays admissible ) qualified financial statements , of the standard constituent entities of an MNE group that are located in a jurisdiction for a particular fiscal year, means the financial accounts or financial statements of the standard constituent entities, if (a) the financial accounts or financial statements are (i) used to prepare the consolidated financial statements of the ultimate parent entity for the particular fiscal year, (ii) prepared in accordance with an acceptable financial accounting standard or authorized financial accounting standard, if the information contained in those statements is maintained based on that accounting standard and is reliable, (iii) if a standard constituent entity is not included in the consolidated financial statements of the MNE group on a line-by-line basis solely due to size or materiality grounds, the financial accounts of the standard constituent entity that are used for preparation of the MNE group’s country-by-country report, or (iv) if a standard constituent entity is a permanent establishment that does not have separate financial accounts described in subparagraph (i) or separate financial statements described in subparagraph (ii), the separate financial statements prepared by the main entity for the permanent establishment for financial reporting, regulatory, tax reporting or internal management control purposes; and (b) either (i) the financial accounts or statements do not incorporate purchase price accounting adjustments, or (ii) where the financial accounts or financial statements of one or more of the standard constituent entities incorporate purchase price accounting adjustments, it is the case that (A) the MNE group has not submitted a country-by-country report for a fiscal year beginning after December 31, 2022 and before the particular fiscal year that was based on the standard constituent entity’s financial accounts or financial statements without the purchase price accounting adjustments, or (B) the standard constituent entity was required by law or regulation to change its financial accounts or financial statements to include purchase price accounting adjustments for a fiscal year beginning after December 31, 2022 and that precedes or is the particular fiscal year. ( états financiers admissibles ) qualified person means (a) in respect of an ultimate parent entity that is a flow-through entity, a holder described in any of paragraphs 20 (1)(a) to (c); and (b) in respect of an ultimate parent entity that is subject to a deductible dividend regime, a dividend recipient described in any of paragraphs 21 (1)(a) to (c). ( personne admissible ) qualified substance-based income exclusion amount , of an MNE group for a jurisdiction for a fiscal year, means the substance-based income exclusion amount of the MNE group for the jurisdiction for the fiscal year determined without regard to the eligible payroll costs and eligible tangible asset amount of any standard constituent entity of the MNE group that is located in the jurisdiction that, for the purposes of the group’s qualified country-by-country report (a) is not regarded as a constituen