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ATO implementation of a global and domestic minimum tax

With release of an exposure draft, we're continuing to focus on consultation around our administrative approach.

Published 24 March 2024

On 21 March 2024, the Treasury released the Global and Domestic Minimum Tax exposure draft. The exposure draft materials implement key aspects of the OECD/G20 Two-Pillar Solution. They include:

This measure will apply to multinational enterprise (MNE) groups with annual global revenue of EUR750 million or more from 1 January 2024. However, the measure is not yet law in Australia.

Treasury is seeking feedback on:

  • the exposure draft primary legislation, subordinate legislation and accompanying explanatory material
  • priority issues that would inform the ATO’s administrative approach and public advice, and guidance on this measure
  • interactions between the exposure draft primary legislation and provisions in Australia’s existing income tax law as outlined in the discussion paper.

Have your say, comments can be submitted to Treasury until 16 April 2024 on the primary legislation and discussion paper and until 16 May 2024 on the subordinate legislation. You can see submission guidelines and how to respond on the Treasury consultation links above.

ATO consultation on our administration of the rules with the MNEs likely to be in-scope of the measure and their advisors will recommence as implementation progresses. Information regarding this next stage of ATO consultation will be released shortly.

To date, the ATO has held 25 targeted public consultation meetings on the administrative aspects of the implementation of the GloBE Model Rules and domestic minimum tax.

We also recently started consultations with Digital Service ProvidersExternal Link (DSP). The purpose of these consultationsExternal Link is to collaborate and discuss technical considerations for the implementation of the new rules, including developing systems to allow for lodgment of the GloBE Information Return (PDF, 1.35KB)This link will download a file.

Based on feedback received to date, we expect future ATO consultations will discuss:

  • providing support and guidance to in-scope MNEs to comply with the new rules and further exploring topics of Australian specific administration and interpretation issues, and
  • developing our compliance and engagement approaches recognising some of the compliance challenges posed by rules.

Read more about the feedback and findings we've gathered during our consultation so far on the ATO webpage.

You can direct questions about our administration of the global and domestic minimum tax to