Australia: Legislation providing details on computation of top-up tax under Pillar Two rules

Rules are effective from January 1, 2024.

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January 22, 2025

Treasury published legislation—the Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024—providing details on the computation of the top-up tax under the recently enacted Pillar Two rules, including:

  • Computing and allocating global anti-base erosion (GloBE) income or loss
  • Computing and allocating adjusted covered taxes
  • Application to investment and tax transparent entities
  • Safe harbor provisions
  • Transitional provisions for multinational enterprise (MNE) groups in the initial phases of being in scope of taxation

The rules are effective from January 1, 2024.

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