Frequently Asked Questions
Everything you need to know about GIRN filing in Canada: from who must file to how our service works.
GIRN Basics
What is a GIRN?
A GIRN (Global Information Return Notification) is an information return, not a tax return. Canadian constituent entities that are part of a large multinational enterprise (MNE) group generally must file a GIRN with the Canada Revenue Agency (CRA) through its online API interface to satisfy Pillar Two reporting obligations set out in the Global Minimum Tax Act (GMTA). There is no specific CRA form. Instead, the CRA requires the information to be submitted electronically in a prescribed format. Among other things, the GIRN identifies which group entity is filing the Global Information Return (GIR) and the country where it is filed.
What is the difference between GIRN, GIR, and GMTR?
GIRN: Filed by Canadian entities when the group’s GIR is filed outside Canada. Its primary purpose is to notify the CRA where the GIR is filed and who filed the GIR. GIR: The main group-level Pillar Two return, filed by the ultimate parent or a designated entity. GMTR: Filed only if a Canadian entity owes top-up tax under Canada’s Global Minimum Tax Act (IIR or QDMTT). Most Canadian subsidiaries of foreign-parented groups only need to file the GIRN.
What is Pillar Two and why does it affect Canadian corporations?
Pillar Two is the OECD/G20 framework establishing a global minimum effective tax rate of 15% for large multinational groups. Canada enacted its implementation, the Global Minimum Tax Act, effective for fiscal years beginning after December 30, 2023. Canadian entities within in-scope MNE groups have new reporting obligations starting with the 2024 fiscal year.
What is an MNE group?
MNE stands for Multinational Enterprise. An MNE group is a group of entities operating in more than one jurisdiction, consolidated for financial reporting purposes. Pillar Two applies to MNE groups with consolidated annual revenue of €750 million or more in at least two of the four preceding fiscal years.
What is a constituent entity?
A constituent entity is any entity or permanent establishment that is part of an MNE group, including the Ultimate Parent Entity. In Canada, a Canadian subsidiary of a large foreign MNE group is a constituent entity and is subject to GIRN filing obligations. A GIRN may also be required for Canadian branches of foreign entities, or partnerships with Canadian-sourced income.
Who is required to file a GIRN in Canada?
Canadian entities that are constituent entities of an MNE group with consolidated annual revenue of €750 million or more in at least two of the four preceding fiscal years must file a GIRN with the CRA.
Does every Canadian subsidiary in a large MNE group need to file separately?
Under the default rules, each Canadian constituent entity files its own GIRN. However, Canada allows local filing simplifications where a single designated filing entity can file on behalf of all Canadian entities in the group. Contact us if you need help with multi-entity coordination.
Our parent company is in the US / UK / EU. Do we still need to file the GIRN in Canada?
Yes. The GIRN obligation applies regardless of where the Ultimate Parent Entity is located. If your Canadian subsidiary is part of an MNE group exceeding the €750 million threshold, a Canadian GIRN filing is required.
What if our Canadian entity had no Canadian revenue in the year?
The filing obligation is based on the MNE group's total consolidated revenue, not the Canadian entity's standalone revenue. Even a dormant Canadian subsidiary may be required to file the GIRN if the group crosses the threshold.
Are financial institutions or insurance companies treated differently?
Certain sector-specific exclusions and adjustments apply under the GloBE rules for regulated financial services entities. We recommend confirming applicability with your tax advisor. For standard industrial/commercial entities, the general GIRN rules apply.
Deadlines & Penalties
What is the GIRN filing deadline?
The GIRN must generally be filed within 15 months of the end of the fiscal year. For the first transition year, the deadline is extended to 18 months. For a December 31, 2024 fiscal year-end, the first GIRN is due June 30, 2026.
What are the penalties for late or missed GIRN filing?
The CRA can impose penalties of up to $25,000 per month to a maximum of $1,000,000 for failure to file or late filing of the GIRN. These penalties may apply per entity, not per group, so the stakes are significant.
Can we request an extension?
The CRA's standard practice for information returns is that extensions are not routinely granted. However, a due-diligence defence may reduce or eliminate penalties if you can demonstrate reasonable efforts to comply. Filing before the deadline is always the safest approach.
Can we file an amended GIRN if we made an error?
Yes. If errors are discovered after acceptance, you can file a corrected/amended GIRN (Global Information Return Notification) through the CRA SERS API. It is better to file a timely-but-corrected return than to miss the deadline. Contact support@pillar2.info for amendment assistance and pricing.
How Pillar2 Pathway Works
How does Pillar2 Pathway file the GIRN?
We use the CRA's authorized T2 Internet Filing API (the SERS, Software-Enhanced Return Service) to transmit your GIRN data directly to the CRA in their prescribed format. You complete a short, guided questionnaire; we generate the JSON formatted data package and transmit it in real time. You receive a CRA acknowledgement receipt immediately.
Do I need to be a client of an accounting firm to use this service?
No. Pillar2 Pathway is a direct business-to-customer service. No accounting firm engagement is required. However, we always recommend that you speak to an advisor to answer Pillar Two technical and administrative questions.
How long does the filing process take?
Most users complete the questionnaire in under 10 minutes once they have their data ready. Transmission to the CRA via our API is near instant. In most cases your GIRN is filed, acknowledged, and confirmed the same day.
Is my data secure?
Yes. All data is encrypted in transit (TLS 1.3) and at rest. We are incorporated in Ontario, Canada and subject to Canadian privacy law. We do not sell or share your data with third parties outside of the required CRA transmission.
What information do I need to have ready before starting?
You will need your 15-digit CRA business (XXXXX XXXX RC XXXX) number, your 15-digit CRA Pillar Two program account (XXXX XXXX PT XXXX) number, fiscal year dates, relevant contact information (email, telephone) of contact person for the filing entity, the name of the qualifying filer of the GIR, and the jurisdiction that the GIR is filed with.
What is a Pillar Two CRA Program Account number?
A Pillar Two CRA program account number (often called a PT number) is a 15-digit identification number issued by the Canada Revenue Agency (CRA). It is used to identify taxpayers that file Pillar Two returns, including the GIRN and other filings under the Global Minimum Tax Act (GMTA). Any entity required to file a GIRN must first obtain a PT program account number from the CRA. This number must be in place before filing. Please note that Pillar2 Pathway cannot register for a PT number on your behalf. CRA instructions for registration are available on its website.
Digital Access Code & CRA Setup
What is a Digital Access Code (DAC)?
A Digital Access Code is a one-time code issued by the CRA that allows first-time filers to authenticate with CRA My Business Account before they have received their permanent online access credentials.
Do I need a DAC to file with Pillar2 Pathway?
Either a DAC or your EFILE credentials is mandatory to file through Pillar2 Pathway — you must have at least one of these before you can submit. If you are a first-time CRA API filer, you will typically use a DAC. If you already have EFILE credentials (an EFILE number and password issued by the CRA), you can use those instead. You do not need to complete any additional software certification or testing stages — Pillar2 Pathway is already authenticated with the CRA on your behalf.
What are EFILE credentials?
EFILE credentials are a CRA-issued EFILE number and password that authorize a filer to transmit returns electronically through the CRA's internet filing infrastructure. If your organization (or its tax representative) already holds active EFILE credentials, those can be used in place of a DAC to authenticate your GIRN filing through Pillar2 Pathway. If you do not yet have EFILE credentials and are filing for the first time, the CRA will issue you a DAC as part of the program account registration process.
Pricing & Plans
What do GIRN, GMTR, GIR and GIR Status cost?
GIRN is $279.99 CAD per filing, GMTR is $199.99 CAD per filing, GIR is $2,199.00 CAD per filing, and GIR Status is free through Pillar2 Pathway. Prices cover preparation, validation, and CRA SERS API transmission for that return. Taxes may apply.
Can I file for multiple entities?
Yes. Each entity and filing is charged separately at the rate for the return type you choose. For unusual volume or bespoke arrangements, email support@pillar2.info.
When am I charged?
We place a temporary authorization on your card when you submit GIRN or GMTR. You are only charged when the CRA accepts your filing and returns a confirmation number. If the CRA does not accept your filing, the hold is released and you are not charged. You can usually correct your form and resubmit using the same authorization while the hold remains active.
Do you offer refunds?
If the CRA does not accept your filing, you are not charged, the authorization is released automatically. If a filing is rejected by the CRA due to a technical error on our end, we will correct and re-transmit at no additional charge. Refunds are available if a filing cannot be completed for reasons within our control.
Still have questions?
Our team is happy to help. Email us at support@pillar2.info or explore our Pillar Two Glossary.
File Your GIRN: $279.99