Canada’s Department of Finance announced that the Fall Economic Statement Implementation Act, 2023 (Bill C-59) and the Budget Implementation Act, 2024, No. 1 (Bill C-69) received royal assent on 20 June, 2024.
The key measures from the 2023 Fall Economic Statement is to help make life more affordable, build more homes, and ensure the nation’s economic growth is shared by all.
The adoption of Bill C-69 delivers on the federal government’s plan to build a Canada that works for every generation.
The key measures provision of the Budget Implementation Act 2024, No. 1 introduces the Global Minimum Tax Act, which enforces a 15% global minimum tax under Pillar Two for qualifying multinational enterprise groups (MNEs) starting on or after 31 December, 2023.
The main provisions of the Fall Economic Statement Implementation Act 2023 include:
- The introduction of a 3% digital services tax (DST) under the Digital Services Tax Act. The DST will not come into force as the Governor in Council has not set a date. However, it will not be implemented before 1 January, 2024;
- The introduction of the earnings-stripping rule under the BEPS Action 4 guidelines, which restricts the deduction of net interest expenses to a fixed ratio of tax EBITDA. This ratio is initially set at 40% for fiscal years commencing on or after 1 October, 2023, and will be reduced to 30% for fiscal years starting on or after 1 January, 2024;
- The provisions to enforce hybrid mismatch rules under BEPS Action Two guidelines to address deduction/non-inclusion discrepancies.
