Australia: Consultation on draft legislation amending Pillar Two rules

Consultation closes November 21, 2025

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october 28, 2025

Treasury released for consultation draft legislation amending the Pillar Two rules to incorporate Organisation for Economic Cooperation and Development (OECD) administrative guidance.

The draft legislation (Taxation (Multinational—Global and Domestic Minimum Tax) Amendment (2025 Measures No.1) Rules 2025) would amend provisions in the Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024, including:

  • Clarification of the limited circumstances in which securitization entities would be liable to pay undertaxed profits rules top-up tax
  • Insertion of an equity investment inclusion election and related rules on qualified flow-through tax benefits
  • Minor amendments to the domestic minimum tax provisions
  • Clarification of the investment entity transparency election for regulated mutual insurance companies

The consultation on the draft legislation closes November 21, 2025.

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