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Australia: Final rules on exemptions from obligation to file Pillar Two tax returns

Final rules generally are the same as draft rules published in August 2025.

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february 2, 2026

The Australian Taxation Office (ATO) on December 22, 2025, published final rules relating to the exemptions from filing domestic minimum tax (DMT) returns and income inclusion rule (IIR)/undertaxed profits rule (UTPR) returns (Taxation Administration (Exemptions from Requirement to Lodge Australian IIR/UTPR Tax Return and Australian DMT Tax Return) Determination 2025).

The rules were published in draft form in August 2025 (read TaxNewsFlash), and apart from minor clarifying changes, the filing exemptions in the final rules are the same as the draft.


For more information, contact a KPMG tax professional in Australia:

Alia Lum | alum@kpmg.com.au

Amanda Maguire | amaguire@kpmg.com.au

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