Tax Insights: Are you prepared to file Pillar Two returns without using forms?

Issue 2026-04

In brief

What happened? 

In January 2026, the Canada Revenue Agency (CRA) released a global minimum tax submission guide and instructions on the three filings required under the Global Minimum Tax Act (GMTA). Collectively referred to as the GMTA returns, they include:

• GLoBE Information Return (GIR)
• Global Minimum Tax Return (GMTR)
• GIR Notification (GIRN)

The first filing deadline for the GMTA returns is June 30, 2026. It applies to in‑scope taxpayers that have a fiscal year that ended in 2024.

The CRA will not be publishing forms to file the GMTA returns (unlike the returns and forms required to be filed under the Income Tax Act). Instead, the GMTA returns must be filed through the CRA’s Application Programming Interface (API) using the schemas provided in the submission guide.

Why is it relevant?

Many taxpayers expected the CRA to release the GMTA returns as forms that could be completed in a PDF format. Without forms, taxpayers will need to consider how to prepare the required information in the relevant schema format and complete the validation process to enable them to submit the returns directly to the CRA.  

Action to consider

In-scope taxpayers should consider whether they will develop an in‑house process to submit the relevant GMTA returns to the CRA. If they intend to submit these returns themselves, they must start engaging their information technology department to build the interface and complete the validation process to submit the required GMTA returns by the June 30, 2026 deadline. 

In detail

Background

The GMTA implements the “Pillar Two” global minimum tax regime in Canada. It applies to multinational enterprise (MNE) groups with total consolidated group revenue of at least €750 million in two of the prior four fiscal years and is effective for fiscal years of MNEs that begin after December 30, 2023. At least one member of an MNE group that is subject to the GMTA must file one or more of the GMTA returns, which are due:

• within 15 months of the end of the relevant fiscal year, or
• for the first year in which the MNE group is subject to the GMTA, within 18 months of the end of the relevant fiscal year

The first GMTA returns must be filed for the 2024 taxation year and are due by June 30, 2026. (The CRA’s website states that, for any fiscal years beginning after December 30, 2023 and ending before January 1, 2025, the filing due date for the GMTA returns is June 30, 2026.)

For more information on the GMTA, see our Tax Insights “Canada releases Global Minimum Tax Act” (June 21, 2024 update).

The CRA’s process to file the GMTA returns

To file the GMTA returns,¹ in‑scope taxpayers must:

• complete a request form to obtain a detailed global minimum tax submission guide from the CRA on how to file the GMTA returns
• build an interface to submit the GMTA returns using the schemas provided in the submission guide; the schemas are, for:
  • the GIR, an Extensible Markup Language (XML) schema
  • the GMTR and GIRN, a JavaScript Object Notation (JSON) schema
• complete a validation of the schemas in the CRA’s certification testing environment to obtain an API token that will allow the GMTA returns to be submitted
• use the API token, along with the taxpayer’s digital access code or EFILE number and password, to submit the GMTA returns in the production environment

To connect with the CRA’s API, taxpayers can:

• engage a service provider to leverage a third-party product, or
• develop a submission service in‑house (under this option, an entity within the taxpayer group must be able to interact with the CRA’s certification testing environment to obtain the requisite API production token before each GMTA return is submitted)

The takeaway

The deadline for the first year of GMTA tax filings is quickly approaching. In‑scope taxpayers should consider how they intend to file their GMTA returns, in addition to collecting the required data and completing the calculations required under the GMTA. Please contact us to discuss how we can help your business prepare and file the GMTA returns.