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Australia: Administrative amendments to domestic minimum tax provisions

Including amendments regarding conversion of domestic top-up tax calculated in foreign currency to Australian dollars

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March 27, 2026

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

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