Global Minimum Tax Act updated to remove Digital Services Tax Act cross-references in transfer-pricing and filing rules

Plain-language summary · AI-assisted · not legal advice

Two provisions in Canada's Global Minimum Tax Act have been revised to remove references to the Digital Services Tax Act. First, the joint-and-several liability formula for non-arm's-length property transfers no longer counts amounts assessed under the Digital Services Tax Act when calculating the transferee's offset (variable B). Second, the rule blocking refunds until all required returns are filed no longer lists the Digital Services Tax Act as one of the statutes whose returns must be cleared before a refund can issue. These changes narrow the scope of two compliance gating mechanisms. Multinational enterprise groups subject to the global minimum tax should review whether these removals affect how they calculate transfer-related liabilities or manage outstanding refund claims. The amendment also records a new legislative chapter citation, indicating the changes were made through a subsequent federal bill.

Who this affects: multinational enterprise groups subject to global minimum tax · tax compliance and finance teams at large MNEs · in-house counsel advising on cross-border property transfers · advisors handling Global Minimum Tax Act refund claims