Australia: Sample combined Pillar Two return forms

Final combined forms expected to be released in March 2026.

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December 4, 2025

The Australian Taxation Office (ATO) released samples of the combined Pillar Two return forms:

The combined forms incorporate into a single form the GloBE Information Return (GIR) foreign notification form, the income inclusion rule (IIR)/undertaxed profits rule (UTPR) return (AIUTR), and the domestic minimum tax return (DMTR). Although each group entity in a multinational enterprise (MNE) group (including a permanent establishment (PE)) located in Australia has a separate filing obligation, the obligation can be met by nominating a DLE to file on behalf of each entity, and the DLE may file one combined return for all relevant group entities.

The final combined forms are expected to be released in March 2026.

In addition, the ATO on November 26, 2025, finalized guidance (PCG 2025/4) outlining its transitional approach to penalties and expectations for the new Pillar Two filing obligations for applicable MNE groups. The ATO indicated it will apply a “soft-landing” approach for taxpayers making reasonable efforts to comply, in line with OECD guidance. Read TaxNewsFlash

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