Australia: Guidance on Pillar Two filing obligations

Practical compliance guideline on ATO's transitional approach to penalties and expectations for the four new Pillar Two filing obligations

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November 26, 2025

The Australian Taxation Office (ATO) released a practical compliance guideline that sets out the ATO's transitional approach to penalties and expectations for the four new Pillar Two filing obligations for applicable multinational enterprise (MNE) groups.

The guideline provides tailored advice to assist taxpayers to meet their new obligations and provides certainty to taxpayers during the transition period (being any fiscal year beginning on or before December 31, 2026, but not ending after June 30, 2028).

The ATO indicated it will apply a “soft-landing” approach for taxpayers making reasonable efforts to comply, in line with OECD guidance.

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