Canada flag between two tall office buildings

Canada introduces further Pillar Two amendments in Bill C‑31, including new safe harbours and GMTA technical amendments

Tax Alert 2026 No. 31, 21 May 2026

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. 

Access the full content in the PDF attached below.



Previous issues

CRA intends to postpone new administrative position on GST/HST treatment of trailing commissions

On 13 May 2026, the Canada Revenue Agency (CRA) verbally informed various industry groups that it intends to grant a material extension to the implementation deadline for the application of GST/HST to mutual fund trailing commissions.

Budget 2025 implementation bill no. 2 tabled in the House of Commons

On 6 May 2026, the government tabled Bill C-31, Budget 2025 Implementation Act, No. 2.

Employee ownership trusts are here to stay

The federal Spring Economic Update 2026, tabled on 28 April 2026, signals that employee ownership trusts (EOTs) are set to become a permanent fixture.

Government tables the Spring Economic Update 2026 Implementation Act

On 29 April 2026, Bill C-30, Spring Economic Update 2026 Implementation Act, received first reading in the House of Commons.

Newfoundland and Labrador Budget 2026

Newfoundland and Labrador Finance Minister Craig Pardy tabled the province’s fiscal 2026 budget on 29 April 2026.

Federal Spring Economic Update 2026

On 28 April 2026, the Minister of Finance and National Revenue, François-Philippe Champagne, tabled the federal government’s Spring Economic Update 2026, which contains several tax measures affecting individuals and corporations.

    Publications and articles



    Contact us
    Like what you’ve seen? Get in touch to find out more.