In June, we held our fourth Pillar Two pre-lodgment information session, attended by more than 300 participants from Australia and overseas. The session supported multinational enterprise (MNE) groups and their advisers to prepare for Pillar Two lodgment essentials and obligations.
What we covered
The session focused on lodgment requirements and included updates on:
- Australia’s Pillar Two implementation progress and milestones
- key lodgment issues, such as whether you need to create a global and domestic minimum tax account and role before lodging
- lodging the GloBE Information Return (GIR)
- joint ventures.
We saw strong engagement during the session. Most questions were answered by information available on our website. We'll review and update this content over the coming months.
The sections below summarise the key topics and link to relevant resources.
Registrations for Pillar Two
MNE groups don't need to register for Pillar Two before their first lodgment. However, some entities may need to create a Global Domestic Minimum Tax (GDMT) account and role before lodging to nominate a tax agent.
If a tax agent already has client-level access for income tax returns, a GDMT account and role is not required and the agent can lodge the Combined Global and Domestic Minimum Tax Return (CGDMTR).
Requests to create GMDT accounts and roles are being processed, and agents don't need to follow up on nomination.
Lodging the CGDMTR
The CGDMTR combines the foreign lodgment notification, Australian IIR/UTPR tax return (AIUTR) and Australian Domestic Minimum tax return (DMTR) into one form available through ATO online services.
All in-scope taxpayers will receive an automatic 30-day lodgment deferral for the 2024 fiscal year (AIUTR and DMTR only). Payment deferrals must be requested separately.
The API channel is open for onboarding. Check with your Digital Service Provider to confirm they have completed all onboarding with the ATO.
Lodging the GIR
We outlined the GloBE Information Return (GIR) XML file requirements, and how to complete certain elements of the GIR, including:
- when to lodge
- due dates
- the GIR XML schema and validation rules.
The automatic 30-day domestic lodgment deferral doesn't apply to the GIR. However, we may consider a suspension of lodgment enforcement during the transition period. This must be requested separately.
Joint arrangements
We provided an update about GloBE joint arrangements and how the rules apply, including examples of whether arrangements may be subject to potential top-up tax or reporting obligations.
We also addressed common questions and invited attendees to send complex enquiries to our mailbox, noting that further web guidance on joint arrangements is being developed.
Reminders and what’s next
Pillar Two first lodgments for December 2024 balancers were due by 30 June, however there is an automatic 30-day deferral for domestic lodgments in place.
If you are an MNE who is a January 2025 balancer, Pillar Two first lodgments are due by 31 July 2026.
Watch the information session recordingExternal Link if you were unable to attend. If you have technical questions or require support that hasn't been covered in our web content, email us at Pillar2Project@ato.gov.au.
For all the latest updates, visit ato.gov.au/Pillar2.
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