2025 IFA Canada Travelling Lectureship in Montreal. GMTA – practical insights in applying the OECD Model Rules in Canada

Guest Lecturer:
Jean-Charles van Heurck, International Tax and Transaction Services (ITTS), Ernst & Young LLP

Discussant:
Michael Kandev, partner - Tax and Private Equity practices, Davies Ward Phillips & Vineberg LLP

The adoption of the Pillar Two rules by the Inclusive Framework of the OECD in 2021, followed by the enactment of these rules by Canada in June 2024, have created an upheaval of the approach to international taxation. Multinational have undertaken a long and arduous journey to grapple with these novel rules and prepare themselves for the first year where these rules are going to impact them.

During the seminar, we will intend to highlight how the GMTA (Global Minimum Tax Act) is structured, how the mechanics of the rules operate, and illustrate how these rules operate in a Canadian context. We will also briefly discuss next step for Pillar Two – compliance and controversy.