Australia: Targeted consultation on implementation of Pillar Two global minimum tax rules

Focus on potential administration issues

Focus on potential administration issues

The Australian Taxation Office (ATO) is undertaking a targeted consultation with significant global entities and their advisors on the implementation of the OECD global anti-base erosion (GloBE) rules under Pillar Two in Australia, with a focus on potential administration issues.

As explained in a related ATO release, for large multinational groups (with annual global revenue of €750 million or more), the proposed start dates for the 15% global minimum tax will occur over two years as follows:

  • Income inclusion rule (IIR) to apply to income years starting on or after 1 January 2024
  • Undertaxed profits rule (UTPR) to apply to income years starting on or after 1 January 2025

According to the ATO, the implementation of the GloBE rules will require in-scope multinational groups to:

  • Provide new information to adhere to the reporting obligations under the global minimum tax and domestic minimum tax (this may require new systems)
  • File a GloBE information return 18 months after the first year end (15 months for subsequent years)


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