Australia: Consultation on additional draft amendments to Pillar Two rules; recent administrative guidance on Pillar Two
Consultation closes March 13, 2026
Treasury released additional draft amendments to the Australian Pillar Two rules. The main amendment is the inclusion of a foreign currency translation rule. The consultation closes March 13, 2026.
In addition, the Australian Taxation Office (ATO) recently published administrative guidance on Pillar Two, including:
- Confirmation that adoption of the OECD side-by-side package in Australia would require enactment into domestic law and would apply only to fiscal years beginning from January 1, 2026
- Administrative approach for joint operations that are constituent entities (CEs) to file GloBE information returns (GIRs)
- Administrative approach to allocation of domestic minimum tax (DMT) and undertaxed profits rule (UTPR) top-up tax when one or more entities to which top-up tax is allocated are subsidiary members of a tax consolidated group (TCG)
- Guidance on Pillar Two treatment of certain prior-year tax adjustments (PYAs) for pre- and post-regime periods
For more information, contact a KPMG tax professional in Australia:
Alia Lum | alum@kpmg.com.au
Amanda Maguire | amaguire@kpmg.com.au