Global Minimum Tax Act — G-3.3 2
e distribution. ( titre de portefeuille à court terme ) standard constituent entity has the same meaning as in subsection 11 (3). ( entité constitutive type ) stapled structure means an arrangement entered into by the ultimate parent entities of two or more groups under which (a) not less than 50% of the ownership interests in each ultimate parent entity are (by reason of the form of ownership, restrictions on transfer or any other terms or conditions) combined with not less than 50% of the ownership interests in each other ultimate parent entity and cannot be transferred or traded other than in that combined form; (b) if the combined ownership interests of the ultimate parent entities are listed on a securities market, they are quoted at a single price; and (c) financial statements are prepared by one of the ultimate parent entities in which the assets, liabilities, income, expenses and cash flows of all the entities of all the groups are presented together as those of a single economic unit, and those financial statements (i) would be consolidated financial statements if the entities of all the groups were included in a single group and the ultimate parent entity that prepared the financial statements was the ultimate parent entity of that group, and (ii) are required by an applicable regulatory regime of a jurisdiction to be externally audited. ( structure indissociable ) stateless constituent entity means a constituent entity of an MNE group that is either (a) a stateless entity under paragraph 5 (2)(b); or (b) a stateless permanent establishment under paragraph 5 (3)(d). ( entité constitutive apatride ) substance-based income exclusion amount has the same meaning as in subsection 32 (1). ( montant de l’exclusion de revenus fondée sur la substance ) substitute loss carry-forward recapture amount , of a constituent entity that is located in a particular jurisdiction, means an amount if (a) the amount would be a tax loss or a portion of a tax loss (referred to in this definition as the “consumed domestic loss”) of the constituent entity if the consumed domestic loss were not offset against another amount — in respect of the income of another entity (referred to in this definition as the “controlled foreign company”) that is located in a jurisdiction other than the particular jurisdiction and in which the constituent entity holds, directly or indirectly, an ownership interest — that is included, under the controlled foreign company tax regime of the particular jurisdiction, in computing the constituent entity’s taxable income in the particular jurisdiction; and (b) the income tax laws of the particular jurisdiction allow the consumed domestic loss to be recaptured by the constituent entity in subsequent taxation years, by recharacterizing amounts of income of the constituent entity from sources in the particular jurisdiction as amounts in respect of income of the controlled foreign company that are included, under the controlled foreign company tax regime of the particular jurisdiction, in computing the constituent entity’s taxable income in the particular jurisdiction or as amounts of income from another foreign source. ( montant de récupération du report de pertes de remplacement ) substitute loss carry-forward tax credit , of a constituent entity that is located in a particular jurisdiction, means a tax credit, or any portion of a tax credit, of the constituent entity that (a) arises under the income tax laws of the particular jurisdiction in respect of tax paid to the government of a jurisdiction other than the particular jurisdiction by another entity (referred to in this definition as the “controlled foreign company”) that is located in a jurisdiction other than the particular jurisdiction, in which the constituent entity holds, directly or indirectly, an ownership interest, on income (referred to in this definition as the “attributed controlled foreign company income”) of the controlled foreign company that is included