Bill C‑31, Budget 2025 Implementation Act, No. 2, received first reading on 6 May 2026 and contains significant — though mostly previously announced — proposed amendments to Canada’s Global Minimum Tax Act (GMTA) and Income Tax Act. Most notably, Bill C-31 would implement the UTPR (undertaxed profits rule), with some modifications since draft legislative proposals were released for public comment on 12 August 2024, and defer its application by one year.
Bill C-31 also includes numerous amendments from previous draft legislative proposals intended to reflect aspects of the OECD/G20 Inclusive Framework on BEPS administrative guidance, address certain safe harbour measures, coordinate foreign domestic minimum top-up taxes with the Canadian foreign affiliate rules, and make technical and consequential amendments to the Canadian Pillar Two framework.
In this Tax Alert, we provide a brief overview of certain Pillar Two measures included in Bill C-31 and comments on what is not included in the bill.