On 9 May 2023, the Treasurer announced in the 2023–24 Budget that the Australian Government will implement the Organisation for Economic Cooperation and Development (OECD) Global Anti-Base Erosion (GloBE) Model Rules (also known as global minimum tax) and domestic minimum tax. The 15% global minimum tax and 15% domestic minimum tax will apply to large multinationals with annual global revenue of EUR750 million (approximately $1.2 billion) or more.
This measure is not yet law and new legislation will be introduced.
In scope multinational groups will need to:
- provide new information to adhere to the reporting obligations under the global minimum tax and domestic minimum tax (this may require new systems)
- lodge a GloBE Information Return (GIR)
- the GIR will need to be lodged 18 months after the first year end (15 months for subsequent years)
- the OECD have published GIR requirements, for details see GloBE Information ReturnThis link will download a file.
The start dates for the:
- 15% global minimum tax for large multinational enterprises will occur over two years with the
- Income Inclusion Rule to apply to income years starting on or after 1 January 2024, and
- Undertaxed Profits Rule to apply to income years starting on or after 1 January 2025.
- 15% domestic minimum tax to apply to income years starting on or after 1 January 2024.
We have commenced targeted public consultation with selected taxpayers likely to be in scope of the proposed measures and their advisors with a focus on potential administration issues. Consultation is being undertaken in a phased approach:
- Phase 1 with industry groups and their members (July – August 2023)
- Phase 2 with mid-tier firms (August – October 2023)
- Phase 3 with large advisory firms (September – November 2023)
Consultation will not cover matters of policy as Treasury will be developing policy and we will administer the laws once enacted.
All significant global entities (SGEs) and their advisors should start to consider if they are in scope and prepare for the implementation of the Pillar Two GloBE Model Rules in Australia and other jurisdictions.
To participate, see our website for details about the consultation process.
See our website for more information on the implementation of the GloBE rules and domestic minimum tax.
SGEs have your say on the implementation of Pillar Two Global Anti-Base Erosion Model Rules and domestic minimum tax.