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Australia: Legislation to incorporate elements of Pillar Two agreed administration guidance registered

Would incorporate elements of Pillar Two agreed administration guidance released in December 2023, June 2024, and January 2026

July 6, 2026

The government registered the Taxation (Multinational—Global and Domestic Minimum Tax) Amendment (2026 Measures No. 2) Rules 2026, which would make the following amendments to various sections of Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024 to incorporate elements of the Pillar Two agreed administration guidance released in December 2023, June 2024, and January 2026:

  • Section 3-255 to amend the flow‑through entity income allocation rules and related definitions in Chapter 10
  • Section 4-55 to the blended controlled foreign company (CFC) allocation key
  • Section 4-95 to modify the substitute loss carry forward rule
  • Section 8-15 to extend the transition period for the transitional country-by-country (CbC) reporting safe harbor by 12 months

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