We've published a draft Practical Compliance Guideline PCG 2025/D3 Global and domestic minimum tax lodgment obligations – transitional approach and an update to Taxation Ruling TR 2006/11DC Private Rulings for Pillar Two for public consultation until 29 August.
The draft PCG 2025/D3 covers:
- Pillar Two lodgment obligations and due dates
- lodgment deferrals and suspension of lodgment enforcement action
- our approach to failure to lodge penalties and statement penalties during the transition period (fiscal years beginning on or before 31 December 2026 but not including a fiscal year that ends after 30 June 2028).
Consistent with Organisation of Economic Cooperation and Development (OECD) guidance, we'll adopt a soft-landing approach during the transition period, allowing taxpayers to take reasonable measures to meet their obligations.
Updates to TR 2006/11DC include an:
- updated reference to the provisions that are relevant to rulings, including the new Pillar Two provisions
- explanation that the Commissioner may decline to rule on a private ruling application on the Australian income inclusion rule, the undertaxed profits rule, or on domestic minimum tax, if it would be unreasonable to comply with the application, including examples where this might occur.
We’re inviting comments on these drafts from:
- multinational enterprise groups in Australia that may be in-scope of Pillar Two
- tax and legal professionals, advisers and consultants with clients in-scope for Pillar Two.
The consultation is open until 29 August. If you represent one of the above groups, you can provide comments directly to the contact person listed on the draft PCG and TR.
We'll be making:
- further updates to TR 2006/11DC to address recent case law developments and will release another draft for consultation at that time – we'll share progress updates through our Advice under development program
- routine updates to related lodgment and penalties practice statements and taxation rulings to cover Pillar Two – these will be published when available.
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