IDEAS home Printed from https://ideas.repec.org/a/ctf/journl/v71y2023i1p137-158.html
   My bibliography  Save this article

Canadian QDMTT Challenges

Author

Listed:
  • Jinyan Li

    (Osgoode Hall Law School, York University, Toronto)

  • Angelo Nikolakakis

    (EY Law LLP)

  • Jean-Pierre Vidal

    (HEC Montréal)

Abstract

Nobody believes that Canada is a tax haven. The fact remains that the effective tax rate of certain entities could be less than 15 percent. If nothing is done, pillar two could therefore apply, and taxes that naturally accrue to Canada could end up in foreign hands. We must therefore find a solution, and the most obvious is that of adopting a qualified domestic minimum top-up tax (QDMTT). Other solutions are possible, but they seem less attractive. A QDMTT still presents some challenges. These challenges include sharing with the provinces, determining the priority to be given to certain foreign taxes relating to Canadian income (that is, whether those foreign taxes take priority over the QDMTT or vice versa), and estimating certain foreign taxes.

Suggested Citation

  • Jinyan Li & Angelo Nikolakakis & Jean-Pierre Vidal, 2023. "Canadian QDMTT Challenges," Canadian Tax Journal, Canadian Tax Foundation, vol. 71(1), pages 137-158.
    • Handle: RePEc:ctf:journl:v:71:y:2023:i:1:p:137-158
    DOI: https://doi.org/10.32721/ctj.2023.71.1.sym.li.etal
    as

    Download full text from publisher

    File URL: https://www.ctf.ca/EN/Publications/CTJ_Contents/2023CTJ1.aspx
    Download Restriction: no
    File URL: https://libkey.io/https://doi.org/10.32721/ctj.2023.71.1.sym.li.etal?utm_source=ideas
    LibKey link: if access is restricted and if your library uses this service, LibKey will redirect you to where you can use your library subscription to access this item
    ---><---

    Corrections

    All material on this site has been provided by the respective publishers and authors. You can help correct errors and omissions. When requesting a correction, please mention this item's handle: RePEc:ctf:journl:v:71:y:2023:i:1:p:137-158. See general information about how to correct material in RePEc.

    If you have authored this item and are not yet registered with RePEc, we encourage you to do it here. This allows to link your profile to this item. It also allows you to accept potential citations to this item that we are uncertain about.

    We have no bibliographic references for this item. You can help adding them by using this form .

    If you know of missing items citing this one, you can help us creating those links by adding the relevant references in the same way as above, for each refering item. If you are a registered author of this item, you may also want to check the "citations" tab in your RePEc Author Service profile, as there may be some citations waiting for confirmation.

    For technical questions regarding this item, or to correct its authors, title, abstract, bibliographic or download information, contact: Jim Lyons (email available below). General contact details of provider: https://www.ctf.ca/EN .

    Please note that corrections may take a couple of weeks to filter through the various RePEc services.

    IDEAS is a RePEc service. RePEc uses bibliographic data supplied by the respective publishers.