Australia: Administrative amendments to domestic minimum tax provisions
Including amendments regarding conversion of domestic top-up tax calculated in foreign currency to Australian dollars
Treasury has registered Taxation (Multinational—Global and Domestic Minimum Tax) Amendment (2026 Measures No.1) Rules 2026, which introduces administrative amendments to the domestic minimum tax provisions in Chapter 2 of the Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024, including:
- Minor amendments to clarify the operation of domestic top‑up tax in respect of stateless entities
- Amendments regarding the allocation of domestic top‑up tax amounts from subsidiary members of tax consolidated groups to their head entities
- Minor amendments to provide that covered taxes imposed on a reverse hybrid entity or hybrid entity in Australia will be allocated to that entity for the purposes of computing a domestic top‑up tax amount
- Amendments regarding the conversion of amounts of top‑up tax calculated in a foreign currency to Australian dollars based on the foreign exchange rate on the last day of the fiscal year