Canada · Pillar Two · Partly in force

Canada Pillar Two obligations

Canada imposes 3 separate filing obligations under Pillar Two. The earliest is GloBE Information Return, due 18 months after the first fiscal year; 15 months thereafter. Transitionally 30 June 2026 for years ending on or before 31 Dec 2024.. Checked against the authority on 3 October 2026.

Checked 3 October 2026 Primary-sourced 3 separate filing obligations

IIR and domestic top-up tax are law. The UTPR is NOT — it sits in a bill still before Parliament.

Access gate — clear this before anything can be filed

PT program account + mandatory schema validation

A validation of all schemas in the CRA Certification Testing environment is mandatory to obtain an API token. No token, no filing. Registration opened 20 October 2025; CT available from 5 January 2026.

What is in force in Canada

ChargeLocal nameIn force from
IIRGlobal minimum tax (Part 2, GMTA)Fiscal years beginning on or after 31 Dec 2023
UTPRNot in force — proposed in Bill C-31Proposed for fiscal years beginning on or after 31 Dec 2025
DomesticDomestic minimum top-up tax (Part 3, GMTA)Fiscal years beginning on or after 31 Dec 2023

The 3 separate filing obligations

GloBE Information Return

Also: GIR

The OECD-format information return.

Who files
A designated filing entity in Canada, the UPE if Canadian, or each constituent entity or an appointed designated local entity
Deadline
18 months after the first fiscal year; 15 months thereafter. Transitionally 30 June 2026 for years ending on or before 31 Dec 2024.
Channel
API submission only, XML. Acceptance confirmed about 24 hours after submission.

Get ready to file — Canada Revenue Agency ↗

GIR Notification

Notification that the GIR is being filed by a qualifying foreign filing entity.

Who files
Canadian constituent entities, or an appointed designated local entity
Deadline
Same 18/15-month rule; 30 June 2026 transitionally
Channel
API, JSON schema

Who must file — Canada Revenue Agency ↗

Global Minimum Tax Return

The self-assessment return for liability under Part 2 or Part 3.

Who files
Each person with a liability, or an appointed Canadian filing entity
Deadline
Tied to the GIR due date for the fiscal year
Channel
API, JSON schema

Who must file — Canada Revenue Agency ↗

Penalties

Avoidance penalty the lesser of 50% of the amount avoided and $100,000. General penalty $2,500 where no other is specified. Failure-to-file offences $2,000 to $40,000 and up to 12 months imprisonment. Administrative failure-to-file amounts under ss. 97–99 unconfirmed.

What catches groups out in Canada

  • Canada's UTPR had passed second reading and a Senate pre-study as at 3 October 2026 and sits in committee. Royal assent may well be near, so date any client-facing statement that it is not in force.
  • A separate 30-day clock applies where the CRA notifies that no GIR was received by the exchange date.
  • Penalty concession runs 1 July to 31 December 2026 where the group filed centrally and notified the CRA by 30 June 2026; penalties may apply from 1 January 2027.

Recent changes affecting Canada

  • 2026-12-31 — End of the CRA concession not to penalise a missing GIR where the group filed centrally and notified the CRA by 30 June 2026. Penalties may apply from 1 January 2027.
  • 2026-06-30 — First Canadian filing deadline for fiscal years beginning on or after 31 December 2023 and ending on or before 31 December 2024.
  • 2026-05-06 — Bill C-31 introduced, containing Canada's UTPR for fiscal years beginning on or after 31 December 2025. Not yet enacted.
  • 2026-01-29 — Finance Canada releases legislative proposals relating to the Global Minimum Tax Act.

All dated changes →

Common questions

What must be filed in Canada under Pillar Two?

3 separate obligations: GloBE Information Return; GIR Notification; Global Minimum Tax Return.

When is the GloBE Information Return due in Canada?

18 months after the first fiscal year; 15 months thereafter. Transitionally 30 June 2026 for years ending on or before 31 Dec 2024.. Filed by: A designated filing entity in Canada, the UPE if Canadian, or each constituent entity or an appointed designated local entity. Channel: API submission only, XML. Acceptance confirmed about 24 hours after submission..

When is the GIR Notification due in Canada?

Same 18/15-month rule; 30 June 2026 transitionally. Filed by: Canadian constituent entities, or an appointed designated local entity. Channel: API, JSON schema.

What access is needed before filing in Canada?

PT program account + mandatory schema validation. A validation of all schemas in the CRA Certification Testing environment is mandatory to obtain an API token. No token, no filing. Registration opened 20 October 2025; CT available from 5 January 2026.

What are the penalties in Canada?

Avoidance penalty the lesser of 50% of the amount avoided and $100,000. General penalty $2,500 where no other is specified. Failure-to-file offences $2,000 to $40,000 and up to 12 months imprisonment. Administrative failure-to-file amounts under ss. 97–99 unconfirmed.

Where this comes from

Every row on this page was checked against the authority's own published page on 3 October 2026. Verified against CRA pages and the Parliament of Canada bill record.

Cite this page

Saurabh Satija, “Canada Pillar Two filing obligations”, https://saurabhsatija.com/pillar-two-canada, accessed [date].

Quotation and citation with attribution and a link are welcome. The underlying data is open as JSON and as plain text.

Other Pillar Two jurisdictions

United Kingdom · Ireland · Netherlands · Belgium · Germany · Spain · Italy · Luxembourg

All 21 entries in the tracker →

How many of these are actually yours?

This page shows what Canada requires. The scoping tool takes your whole footprint and returns every filing it triggers, in deadline order, with the access prerequisites attached. About thirty seconds.