How to manage GMTA compliance obligations ahead of filing deadline

An absence of prescribed forms from the Canada Revenue Agency (CRA) could complicate compliance obligations under the new Global Minimum Tax Act (GMTA).

The GMTA requires in-scope multinational enterprise (MNE) groups to report detailed financial data and prove they meet a minimum effective tax rate of 15 per cent in the jurisdictions where they operate.

With the first GMTA returns due by June 30, 2026, organizations must contend with myriad requirements from the act and recent CRA submissions guidelines—without prescribed forms.

As MNE groups evaluate their strategies, in consultation with the appropriate advisors, it’s critical that this data-driven exercise is done carefully and the filing requirements are adhered to properly. Otherwise, they could face significant penalties for late filings or failure to file.

GMTA overview

The federal government introduced the GMTA to implement Pillar II framework outlined by the Organization of Economic Co-operation and Development (OECD).

The act covers MNE groups with €750 million or more in consolidated revenue in at least two of the four preceding fiscal years with at least one Canadian entity; the GMTA specifically uses euros for this threshold.

Canada also enacted an income inclusion rule (IRR) and a domestic minimum top up tax (DMTT)—in line with Pillar II recommendations—included in the GMTA.

The GMTA requires in scope MNE groups to submit up to three filings to the CRA:

• GloBE information return (GIR): The OECD developed a standardized GIR that contains certain information on the MNE group. The GIR can be filed on behalf of the group by the ultimate parent entity of an MNE group if it is located in Canada or another designated filing entity appointed by the group.
• Global minimum tax return (GMTR): A person with a global minimum tax liability must file a GMTR, which is separate from a GIR but has the same due date. This would apply where an entity is liable to pay tax in Canada under the IRR or DMTT rule. Like the GIR, where more than one entity is required to file based on an amount payable under the IRR or DMTT, an MNE group may appoint one such entity to file the respective return provided they are a resident of Canada.
• GIR notification: Each constituent entity of a qualifying MNE group located in Canada must notify the minister of national revenue of the identity of any qualifying foreign filing entity and the jurisdiction in which it is located. Similar to the above filings, an MNE group may appoint a single constituent entity located in Canada to provide this notification.

The filing due date for the GIR, GMTR, and GIR notifications is June 30, 2026 for fiscal periods that began on or after Dec. 31, 2023 and ended on or before Dec. 31, 2024. For years other than the first year of a GMTA filing, returns will be due within 15 months after the end of the relevant fiscal year.

Registration and filing

Members of MNE groups located in Canada generally must register with the CRA for a global minimum tax program account if they are required to file a return or notification under the GMTA or have a tax liability under the GMTA.

According to the CRA’s submission guidelines released in January 2026, all GMTA filings must be submitted electronically with an application programming interface (API) token provided by the CRA.

GIR filings require the use of an extensible markup language (XML) schema, while the GMTR and GIR notification need to be filed using a JavaScript object notation (JSON) schema.

MNE groups with filings obligations must also request a submission guide from the CRA in advance of filing and build an interface to submit the GIR, the GMTR and GIR notification. A validation of schemas is required before the CRA provides the necessary API token.