We held our first open information session in August about our implementation of a global and domestic minimum tax (Pillar Two). Our focus was on engaging with multinational enterprise (MNE) groups that may be in-scope of the measure, and with tax advisers providing specialist services around Pillar Two. This ongoing engagement will help us to develop the guidance and support we’ll provide for this measure.
What we covered
Our information session covered:
- an overview of the Pillar Two rules
- Australia’s legislation and guidance
- key taxpayer obligations
- how we're supporting the market and what’s coming next.
Where to find information
Many of the topics that attendees raised at the open information session are already addressed in our web content, including those covered below. We’ll continue to update our website and expand our guidance.
Permanent establishments
You can visit When and how the Pillar Two rules apply to learn how the Pillar Two rules apply to permanent establishments in Australia.
GloBE information return (GIR)
It's expected that Australia will sign the GIR Multilateral Competent Authority Agreement, however this is a matter for Treasury not the ATO.
We’ll continue to update our web content about the GIR in the coming months.
Lodgment requirements
One of the main topics that attendees raised was lodgment obligations. In our web content you can find details on:
- who can lodge on behalf of a permanent establishment
- lodging the GIR, including if the constituent entity applies for safe harbour
- lodging information for constituent entities that meet the transitional safe harbour
- lodging requirements for Australian entities where there are multiple subsidiaries in Australia for the one MNE group
- nominating a designated filing entity included in the foreign lodgment notification.
You can visit Lodging, paying and other obligations for Pillar Two for information on the topics above.
Legislative Instrument
Since the information session we released a draft LI 2025/D17. It sets out the circumstances where a group entity of an in-scope multinational enterprise (MNE) does not need to lodge the Australian IIR/UTPR Tax Return and the DMT Tax Return for a fiscal year.
What’s next?
We’ll be holding another Pillar Two open information session in November. We'll share more details, including how to register, closer to the date.
We will regularly update our website with expanded guidance, including information on safe harbours and consolidations. We are expecting to publish updates in the next few weeks.
If you have technical questions or need support, please email us at Pillar2Project@ato.gov.au
For all the latest updates on Pillar Two, visit ato.gov.au/Pillar2.
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