Introducing a Global Minimum Tax (Pillar Two) in Canada: Some Knowns and Unknowns

Jinyan Li, Osgoode Hall Law School of York University

Canadian Tax Journal forthcoming.

The author thanks members of an informal Pillar Two study group (Robin Boadway, Catherine Brown, Wei Cui, David Duff, Ken Klassen, Jack Mintz, Amin Mawani and Jean-Pierre Vidal) for their discussions about Pillar Two and its implications for Canada. She recognizes the financial support from SSHRC, Canadian Tax Foundation, Osgoode Hall Law School and HEC Montreal to organize a Pillar Two symposium and scholarly roundtable which enriched her thinking about Pillar Two. She thanks Sylvia Masiye for her research assistance, and Geoffrey Turner and Scott Wilkie for their comments on an earlier draft of this paper. She is indebted to Brian Arnold, Angelo Nikolakakis and Jean-Pierre Vidal for numerous conversations about Pillar Two. The views and errors are, however, hers alone.


This paper provides a high-level overview of Pillar Two Global Minimum Tax in terms of its policy objectives, technical design and implications for Canada. After teasing out some significant known and unknown challenges, it offers some thoughts on whether, and if so, how and when Canada can proceed with implementation.