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Australia: Consultation on draft amendments to global and domestic minimum tax rules

Consultation closes May 22, 2026.

may 5, 2026

Treasury released for consultation draft amendments to Australia’s global and domestic minimum tax rules (Taxation (Multinational—Global and Domestic Minimum Tax) Amendment (2026 Measures No.2) Rules 2026).

The amendments would make minor changes to the law to keep it consistent with the OECD guidance, including:

  • Refining the allocation of income and taxes for flow-through and hybrid entities
  • Clarifying certain tax allocation rules
  • Modifying when substitute loss carry-forward deferred tax assets arise
  • Adjusting the operation of safe harbor rules

The consultation closes May 22, 2026. 

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