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Australia: Updated guidance addressing global and domestic minimum tax filing obligations

Outlines ATO’s practical administrative approach to enforcing penalties for global and domestic minimum tax filing obligations

July 13, 2026

The Australian Taxation Office (ATO) released an updated practical compliance guideline addressing its transitional approach to global and domestic minimum tax filing obligations.

PCG 2025/4 outlines the ATO’s practical administrative approach to enforcing penalties for global and domestic minimum tax filing obligations during the transition period.

The update incorporates ATO guidance on the OECD’s common understanding for jurisdictions implementing the global minimum tax in 2024.

Transitional administrative relief

As an implementing jurisdiction, Australia has agreed to provide relief when both of the following conditions are met:

  • The GloBE information return (GIR) has been centrally filed in one of the jurisdictions listed in the annex by the relevant filing deadline
  • The GIR notification has been filed in the local jurisdiction by the relevant deadline

When those conditions are satisfied, Australia has agreed to:

  • Waive penalties that might otherwise apply with respect to local GIR filing obligations
  • Not enforce local GIR filing obligations before the relevant GIR exchange deadline

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