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Income Taxes
6 Months Ended
Apr. 30, 2024
Income Taxes [Abstract]  
Income Taxes
NOTE 17: INCOME TAXES
International Tax Reform – Pillar Two Global Minimum Tax
The OECD published Pillar Two model rules as part of its
 
efforts toward international tax reform. The
 
Pillar Two model rules provide for the implementation of a
15% global minimum tax for large multinational
 
enterprises, which is to be applied on a
 
jurisdiction-by-jurisdiction basis. Pillar
 
Two legislation has been enacted or
substantively enacted in certain jurisdictions
 
in which the Bank operates. On May 2, 2024,
 
the Government of Canada introduced Bill
 
C-69, which includes the
Global Minimum Tax Act
 
addressing the Pillar Two model rules. The rules will
 
be effective for the Bank in Canada and other jurisdictions
 
for the fiscal year
beginning on November 1, 2024. The Bank
 
is assessing its potential exposure
 
to Pillar Two income taxes.
Other Tax Matters
The Canada Revenue Agency (CRA), Revenu
 
Québec Agency (RQA) and Alberta
 
Tax and Revenue Administration (ATRA) are denying certain dividend and
interest deductions claimed by the Bank.
 
During the quarter, the RQA reassessed the Bank for $
1
 
million of additional tax and interest in respect
 
of its 2018
taxation year. As at April 30, 2024, the CRA has reassessed
 
the Bank for $
1,661
 
million for the years 2011 to 2018, the RQA has reassessed the
 
Bank for
$
52
 
million for the years 2011 to 2018, and the ATRA has reassessed the Bank for $
71
 
million for the years 2011 to 2018. In total, the Bank has been reassessed
for $
1,784
 
million of income tax and interest. The Bank
 
expects to continue to be reassessed for open
 
years. The Bank is of the view that its tax filing
 
positions
were appropriate and filed a Notice of Appeal
 
with the Tax Court of Canada on March 21, 2023.