Australia: Updated guidance on Pillar Two minimum tax rules

Including overview of mechanics for calculating top-up tax

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May 19, 2025

The Australian Taxation Office (ATO) released updated guidance regarding the Pillar Two minimum tax rules, including:

  • Guidance about how the ATO will administer potential amendments to Australian law to address inconsistencies
  • Overview of the mechanics for calculating top-up tax
  • Additional information on how the rules apply, including in respect of specific entities
  • Additional information and examples about filing, payment, and record-keeping obligations
  • How Pillar Two interacts with other provisions

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