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Australia: Consultation on additional draft amendments to Pillar Two rules; recent administrative guidance on Pillar Two

Consultation closes March 13, 2026

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march 4, 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

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