Global Minimum Tax Act — G-3.3 2
 GloBE net ) net GloBE loss , of an MNE group for a jurisdiction for a fiscal year, means the absolute value of the negative amount, if any, that would be determined, in the absence of section 8 , by the formula A − B where A is the total of all amounts each of which is the GloBE income for the fiscal year of a standard constituent entity of the MNE group that is located in the jurisdiction; and B is the total of all amounts each of which is the GloBE loss for the fiscal year of a standard constituent entity of the MNE group that is located in the jurisdiction. ( perte GloBE nette ) net income or loss from international shipping has the same meaning as in subsection 19 (2). ( résultat net de transport maritime international ) non-marketable transferable tax credit means all or a portion of a tax credit (other than a qualified refundable tax credit) that (a) in respect of an originator, is not a marketable transferable tax credit but that is transferable in whole or in part; and (b) in respect of a purchaser, is not a marketable transferable tax credit. ( crédit d’impôt transférable non commercialisable ) non-profit organization means an entity, if (a) the entity is established and operated in the jurisdiction where it is located (i) exclusively for religious, charitable, scientific, artistic, cultural, athletic, educational or other similar purposes, or (ii) as a professional organization, business league, chamber of commerce, labour organization, agricultural or horticultural organization, civic league or an organization operated exclusively for the promotion of social welfare; (b) substantially all of the income of the entity from the activities referred to in paragraph (a) is exempt from income tax in the jurisdiction where the entity is located; (c) the entity has no shareholders or members that have a proprietary or beneficial interest in its income or assets; (d) the income or assets of the entity may not be distributed to, or applied for the benefit of, a private person or non-charitable entity other than (i) pursuant to the conduct of the entity’s charitable activities, (ii) as payment of reasonable compensation for services rendered or for the use of property or capital, or (iii) as payment representing the fair market value of property that the entity has purchased; (e) on termination, liquidation or dissolution of the entity, all of the entity’s assets must be distributed or revert to a non-profit organization or to the government (including any governmental entity) of the jurisdiction where it is located or any political subdivision thereof; and (f) the entity does not carry on a trade or business that is not directly related to the purposes for which it was established. ( organisation à but non lucratif ) non-qualifying gain or loss means the lesser of (a) the portion of any gain or loss, arising in respect of a transfer of assets and liabilities in connection with a GloBE reorganization, that is subject to income or profits tax in the jurisdiction where the transferor is located; and (b) the portion of the gain or loss that is reflected in the financial accounts. ( profit ou perte non admissible ) OECD means the Organisation for Economic Co-operation and Development. ( OCDE ) OECD Model Tax Convention means the Model Tax Convention on Income and on Capital: Condensed Version 2017 , published by the OECD on December 18, 2017, as amended from time to time. ( Modèle de Convention fiscale de l’OCDE ) origination year means the fiscal year in which the originator of a tax credit satisfies the eligibility criteria for the tax credit under the laws of the jurisdiction granting the tax credit. ( année de création ) originator means the person that engages in the activities that generate a tax credit. ( initiateur ) other comprehensive income , in respect of a constituent entity, means items of income and expense that are recognized outside of the profit or loss account in the financial statements used in determining the