Quick Answer
Canada’s first Global Minimum Tax Act (GMTA) filings are due Tuesday, June 30, 2026. The deadline applies to multinational enterprise (MNE) groups with at least €750 million in consolidated revenue in two of the four preceding fiscal years, for fiscal years beginning on or after December 31, 2023 and ending on or before December 31, 2024.
In-scope groups must file up to three separate returns — the GloBE Information Return (GIR), the Global Minimum Tax Return (GMTR), and a GIR notification — electronically through the Canada Revenue Agency’s Application Programming Interface using XML or JSON schemas. Non-filing penalties start at $25,000 per month and cap at $1 million per return.
Why the June 30, 2026 Deadline Matters Right Now
The Global Minimum Tax Act (GMTA) is Canada’s version of the international Pillar Two rules, and its first filing deadline lands on Tuesday, June 30, 2026. That deadline covers fiscal years ending in 2024, which means large multinational groups have already lived through the reporting period. The work now is assembling data and filing.
Three things make this deadline unusually stressful. First, the Canada Revenue Agency (CRA) has published no PDF or paper form for these returns; every filing must be submitted through the CRA’s Application Programming Interface (API) using structured data schemas. Second, non-filing penalties begin at $25,000 per month and reach $1 million per return quite quickly. Third, many Canadian businesses only learned they are in scope after a foreign parent company or auditor raised it, leaving little time to prepare. For a broader view of the compliance landscape, see what small businesses need to watch in 2026.
Quick Start: Pick Your Path
Employees, sole proprietors, and self-employed contractors are not affected. Personal T1 or self-employment reporting continues as normal. You can safely close this article.
Small or mid-sized Canadian private companies below the threshold are not in scope. Standard T2 corporate income tax and HST or GST obligations continue, but no GMTA filing is required.
Contact your ultimate parent entity’s tax function immediately. Even with no top-up tax liability, you may still need to file a GIR notification identifying the group’s foreign filer.
The full compliance obligation applies. Register with the CRA for a global minimum tax program account, prepare up to three returns, and submit them by June 30, 2026.
Who Has to File: The €750 Million Scoping Test
Two details catch groups off guard. First, the threshold is stated in euros, not Canadian dollars. Do not convert the €750 million figure to CAD when checking whether you meet the test. Second, falling below the threshold in the current year does not remove a group from scope if the historical look-back years still qualify. Mergers, acquisitions, and divestitures can change the outcome in either direction.
Three terms will appear throughout your compliance work. A constituent entity is any entity consolidated into the MNE group’s financial statements at the ultimate parent level. The ultimate parent entity (UPE) sits at the top of the group. A designated filing entity is a constituent entity appointed by the group to file returns on behalf of the others. For related context on how Canadian SMEs are affected by OECD-driven rules, see how the OECD tax deal affects Canadian SMEs.
Three Filings, One Deadline: GIR, GMTR, and GIR Notification
The GloBE Information Return (GIR) is the OECD’s standardized information return. It contains the group’s structure, jurisdictional GloBE calculations, elections, and safe harbour claims. In Canada, the GIR is submitted through the CRA API using an Extensible Markup Language (XML) schema. The GIR is generally filed by the ultimate parent entity, a designated filing entity, or each Canadian constituent entity where neither of those options applies.
The Global Minimum Tax Return (GMTR) is required only when a top-up tax liability arises in Canada, either under the Income Inclusion Rule (IIR) or the Domestic Minimum Top-up Tax (DMTT). The GMTR is filed via a JavaScript Object Notation (JSON) schema. Where more than one Canadian entity is liable, the group may appoint a single Canadian-resident entity to file for all of them.
The GIR notification is a shorter filing required when a qualifying foreign filing entity, typically a foreign ultimate parent, files the GIR with its own tax authority and Canada has a competent authority agreement in place to exchange it. Each Canadian constituent entity generally must notify the CRA of the identity and jurisdiction of the foreign filer, or appoint a designated notification entity to do so. GIR notifications also use a JSON schema. For an overview of related CRA compliance shifts, see new CRA compliance regulations for businesses.
| Attribute | GIR | GMTR | GIR Notification |
|---|---|---|---|
| Purpose | Reports group structure and jurisdictional GloBE calculations to the CRA. | Reports Canadian top-up tax liability under the IIR or DMTT. | Identifies a foreign entity that is filing the GIR abroad on the group’s behalf. |
| Who files | Ultimate parent entity, designated filing entity, or each Canadian constituent entity. | Each Canadian entity with a liability, or a Canadian-resident designated filer. | Each Canadian constituent entity, or an appointed designated notification entity. |
| CRA schema | XML | JSON | JSON |
| When required | Always for in-scope groups, unless a qualifying foreign filer is exchanging it with the CRA. | Only when a Canadian top-up tax liability arises under the IIR or DMTT. | When a qualifying foreign filer is filing the GIR in its own jurisdiction. |
| Deadline (first year) | June 30, 2026 | June 30, 2026 | June 30, 2026 |
Your Roadmap to the June 30, 2026 Deadline
- 1Confirm scoping and list every Canadian entityVerify the €750 million test against your consolidated financials for the four preceding fiscal years. Prepare a complete list of every Canadian constituent entity in the group, including their fiscal year-ends and CRA business numbers.
- 2Register for a CRA global minimum tax program accountCRA opened program account registration, referred to as the PT program account, in October 2025. Each entity with a filing or notification obligation, or a tax liability under the GMTA, generally must register.
- 3Request the CRA submission guide and API tokenThe CRA released its global minimum tax submission guide in January 2026 and requires filers to request it directly, complete schema validation in the CRA’s certification testing environment, and receive an API token before any live submission.
- 4Assemble the underlying GloBE dataGloBE calculations are jurisdiction-by-jurisdiction and require adjusted covered taxes, GloBE income or loss, and effective tax rate data for every jurisdiction where the group operates. This data is not sitting in your CRA T2 filings; most groups need to build it from consolidated financial data.
- 5Build or engage a schema-compliant filing interfaceBecause CRA has published no PDF form, filers either build an in-house interface that produces XML for the GIR and JSON for the GMTR and GIR notification, or engage a third-party Pillar Two software provider.
- 6Complete certification testing and submit before June 30, 2026Do not leave certification testing to the final week. Groups that discover schema errors in June often cannot resolve them in time. For a broader look at CRA readiness, see our CRA audit preparation guide.
What Happens If You Miss the Deadline
That cap is reached in the fortieth month, but the reputational and audit-flag consequences arrive long before the cap. Two forms of relief may apply. A due-diligence defence is available where the group can demonstrate it exercised all reasonable diligence to comply. In addition, the government has signalled transitional relief for fiscal years beginning before January 1, 2027 and ending before July 1, 2028, where reasonable measures were taken to comply. Separate penalties apply to false statements in a GMTA return.
The general Canadian corporate tax framework continues to apply alongside the GMTA. For background, see Canada’s corporate tax rates explained.
Common Mistakes Canadian Groups Are Making Right Now
Six patterns are showing up repeatedly in the run-up to June 30, 2026. Watch for each of them.
- →Assuming your existing T2 corporate income tax filing satisfies the GMTA. The GMTA operates outside the Income Tax Act and requires separate returns filed through a separate CRA channel.
- →Measuring the €750 million threshold in Canadian dollars. The GMTA specifically uses euros for the scoping test. Using CAD may put you into scope, or out of it, incorrectly.
- →Waiting for a PDF or paper form from CRA. No form will be released. All GMTA filings run through the CRA’s Application Programming Interface using XML and JSON schemas.
- →Assuming the foreign parent’s GIR filing automatically covers Canadian entities. Where a qualifying foreign filing entity files the GIR abroad, each Canadian constituent entity generally must still file a GIR notification identifying that foreign filer.
- →Skipping CRA program account registration. Every Canadian entity with a GMTA filing or tax obligation generally needs a PT program account before submitting.
- →Underestimating certification testing time. Building or configuring a schema-compliant interface and passing CRA validation takes weeks, not days. For cross-border coordination context, see cross-border tax compliance for Canada–US businesses.
Frequently Asked Questions
When is the first Global Minimum Tax filing deadline in Canada?
The first GMTA filing deadline is Tuesday, June 30, 2026. It applies to fiscal years beginning on or after December 31, 2023 and ending on or before December 31, 2024. For later fiscal years, the standard deadline is 15 months after the fiscal year-end.
Does the Global Minimum Tax Act apply to small businesses in Ontario?
No, the GMTA does not apply to typical Ontario small businesses. It only applies to multinational enterprise groups with at least €750 million in consolidated revenue in two of the four preceding fiscal years. Most Canadian SMEs remain subject only to standard corporate tax rules.
What is the €750 million threshold and how is it measured?
The threshold is €750 million or more in consolidated group revenue, measured in euros, in at least two of the four fiscal years preceding the current fiscal year. Canadian dollar conversion is not used for the test. Mergers or acquisitions can change the calculation.
What are the three GMTA returns and which ones do I have to file?
The three returns are the GloBE Information Return (GIR), the Global Minimum Tax Return (GMTR), and the GIR notification. The GIR reports group information. The GMTR reports Canadian top-up tax liability. The GIR notification identifies a foreign filer where the GIR is filed abroad.
Can I file the GMTA return using a paper form or PDF?
No, the CRA has not published a form for GMTA returns. All filings must be submitted electronically through the CRA’s Application Programming Interface using XML for the GIR and JSON for the GMTR and GIR notification.
What happens if my company misses the June 30, 2026 deadline?
Late filing generally attracts a penalty of $25,000 per month or part-month, up to a maximum of $1 million per return. A due-diligence defence and transitional relief may be available for early years where the group demonstrates reasonable compliance efforts.
If our foreign parent files the GIR abroad, do we still have to file anything in Canada?
Yes, in most cases. Where a qualifying foreign filing entity files the GIR in its own jurisdiction, each Canadian constituent entity generally must file a GIR notification with the CRA identifying that foreign filer and its jurisdiction. For related cross-jurisdictional context, see how the US Corporate Transparency Act impacts Canada.
Is Canada’s Global Minimum Tax the same as OECD Pillar Two?
Yes and no. Canada’s GMTA implements the OECD’s Pillar Two framework domestically. It includes a Domestic Minimum Top-up Tax and an Income Inclusion Rule. An Undertaxed Profits Rule has been proposed but is not yet enacted in Canadian law.
Ready to Confirm Whether GMTA Applies to Your Group?
If your group has been swept into the GMTA scope, the immediate priorities are confirming which of the three filings apply, gathering the underlying GloBE data, and coordinating with your ultimate parent or foreign filing entity. ClearWealth Accounting Advisors helps Ontario businesses scope, coordinate, and prepare for GMTA compliance, and manage the CRA relationship throughout.
Book a ConsultationSources & References
- Global Minimum Tax Act (SC 2024, c. 17, s. 81). https://laws-lois.justice.gc.ca/eng/acts/G-3.3/
- Global Minimum Tax Act, section 60 — GIR filing obligation. https://laws-lois.justice.gc.ca/eng/acts/G-3.3/section-60.html
- Canada Revenue Agency — Global minimum tax: get ready to file. https://www.canada.ca/en/services/taxes/excise-taxes-duties-and-levies/global-minimum-tax.html
- PwC Canada — Tax Insights: Are you prepared to file Pillar Two returns without using forms? (January 2026). https://www.pwc.com/ca/en/services/tax/publications/tax-insights/file-pillar-two-returns-without-forms-2026.html
- BDO Canada — Pillar Two: Global minimum tax in Canada (March 2026). https://www.bdo.ca/insights/canada-global-minimum-tax-pillar-two
