24 November 2025 External T.I. 2025-1073271E5 - GMTA - amended CbC report for TCSH

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.

Principal Issues: In determining eligibility for the transitional CbCR safe harbour (TCSH), whether an amended country-by-country (CbC) report is considered as having been filed in accordance with relevant CbC reporting regulations, as defined in section 43 of the Global Minimum Tax Act (GMTA), and if so, whether there is a time limit within which such an amendment should be filed.

Position: A CbC report will not be precluded from having been filed in accordance with "relevant CbC reporting regulations" merely for the reason that it is an amended CbC report. As such, it can be relied on for the purposes of the TCSH to the extent that it meets the requirements of the definition of a "qualified CbC report" in subsection 47(1) of the GMTA and it is filed before the GIR for that fiscal year has been filed. A CbC report that is amended after the GIR for that fiscal year has been filed could require an amendment to the GIR.

Reasons: Based on GIR and CbC reporting rules and guidance.

XXXXXXXXXX									2025-107327
J. Fung, CPA, CA 

November 24, 2025

Dear XXXXXXXXXX:

Re: Amendment of country-by-country reporting for purposes of the transitional CbCR safe harbour under the Global Minimum Tax Act

This letter is in reply to your request for interpretative assistance regarding the amendment of country-by-country (“CbC”) reporting of multinational enterprise (“MNE”) groups for the purposes of determining eligibility for the transitional CbCR safe harbour (“TCSH”) under the Global Minimum Tax Act (“GMTA”).

Under subsection 47(2) of the GMTA, an MNE group can elect the TCSH in respect of a jurisdiction for a particular fiscal year if, among other requirements, a “qualified CbC report” has been filed in relation to the jurisdiction for the particular fiscal year.

A “qualified CbC report” is defined in subsection 47(1) of the GMTA as follows:

qualified country-by-country report, in respect of an MNE group, means a country-by-country report for a jurisdiction for a fiscal year that

(a) is filed in accordance with the relevant country-by-country reporting regulations (as defined in section 43);

(b) is prepared on the basis of qualified financial statements of the standard constituent entities of the MNE group for the jurisdiction for the fiscal year; and

(c) in the case of a multi-parented MNE group, includes the information of all constituent entities of the multi-parented MNE group.

In particular, paragraph (a) requires that a “qualified CbC report” has been filed in accordance with the relevant CbC reporting regulations, as defined in section 43 of the GMTA.

You have asked whether, in a situation where an MNE group previously filed a CbC report in Canada, such a CbC report could be relied on for the purposes of the TCSH as having been filed in accordance with the relevant CbC reporting regulations if it is amended, and if so, whether there is a time limit within which such CbC report should be amended.

CRA response

MNE groups may file an amended CbC report to correct or update any information, in accordance with the CbC reporting rules in the OECD BEPS Action 13 Final Report (footnote 1) as implemented in Canada (footnote 2). As such, an MNE group’s CbC report will not be precluded from having been filed in accordance with the relevant CbC reporting regulations, as defined in section 43 of the GMTA, merely for the reason that the CbC report was amended.

For example, if in the course of preparing its GloBE Information Return (“GIR”) for a particular fiscal year an MNE group discovers that its CbC report was unintentionally filed with incorrect information and it subsequently files an amended CbC report before it files its GIR for that fiscal year, the amended CbC report may be relied upon for the purposes of electing the TCSH for that fiscal year, provided it meets the definition of a “qualified CbC report” in subsection 47(1) of the GMTA.

However, if an MNE group files an amended CbC report for a particular fiscal year after it had filed its GIR for that particular fiscal year and the MNE group elected the TCSH in that GIR, any changes affecting the TCSH conditions or computations may necessitate filing an amended GIR to maintain consistency of filings across regimes. The OECD expects to issue further guidance on amended GIRs as part of the GloBE Implementation Framework (footnote 3).

We trust our comments will be of assistance.

Yours truly,

Charles Dumas
Section Chief
Specialty Tax Division
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch

FOOTNOTES

Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead:

1. Organization for Economic Co-operation and Development (“OECD”) (2015), Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 – 2015 Final Report, OECD/G20 Base Erosion and Profit Shifting (“BEPS”) Project, OECD Publishing, Paris. (http://dx.doi.org/10.1787/9789264241480-en)

2. Implemented through s. 233.8 of the Income Tax Act, with accompanying guidance in CRA publication RC4651, Guidance on Country-by-Country Reporting in Canada.

3. See paragraph 26 of Chapter 8 of the Consolidated Commentary to the Global Anti-Base Erosion Model Rules, last updated May 9, 2025.