In November 2025, we hosted our second information session on implementing the global and domestic minimum tax (Pillar Two). These sessions are designed to support multinational enterprise (MNE) groups, and their advisers prepare for Pillar Two lodgments and obligations. In November we focused on the Australian domestic returns and new web guidance to support compliance.
What we covered
November's session attracted nearly 1,000 attendees from Australia and around the globe. Subjects covered included:
- An overview of lodgment obligations, penalties and our compliance approach.
- A live demonstration of the Combined Global and Domestic Minimum Tax Return (CGDMTR), including two sample scenarios for group entity and designated local entity lodgment.
- Our updated Pillar Two website with guidance on the transitional CBC reporting safe harbour, consolidation and joint arrangements.
During the session we saw strong engagement from attendees, with most questions asked covered by our existing web content. We’ll continue to expand our guidance over the coming months.
Key topics and resources
CGDMTR lodgment
Attendees asked about lodgment channels and entity limits for the CGDMTR. We provided the following advice:
- MNE groups lodging via ATO Online services for business or Online services for agents should note the 20-entity limit.
- Groups lodging via Digital Service Providers offerings have a 300-entity limit. For more information about the API product used to develop this service offering, visit Global and Domestic Minimum Tax APIExternal Link.
- Groups lodging for more than 300 entities should contact us to discuss lodgment options.
For more details on lodgment obligations, visit lodging, paying and other obligations for Pillar Two. We’ll publish further guidance soon on lodgment processes, including entity limits and how to lodge at ato.gov.au/Pillar2.
GloBE Information Return (GIR)
Attendees asked several questions about GIR lodgment, including:
- when to lodge a GIR
- GIR due dates
- the GIR XML schema and validation rules.
For detailed guidance on GIR lodgment, including the foreign lodgment notification required when a GIR is lodged overseas, visit lodging, paying and other obligations for Pillar Two.
For more information about the GIR, including XML schemas, refer to the OECD materials:
- GloBE Information Return (January 2025)External Link
- GloBE Information Return (Pillar Two) XML SchemaExternal Link
- GloBE Information Return (Pillar Two) Status Message XML SchemaExternal Link
We'll continue to update our website with more GIR content in the coming months.
Transitional country-by-country (CBC) reporting safe harbour
In October, we published web guidance on the transitional CBC reporting safe harbour. This guidance explains:
- how to elect to apply the transitional CBC reporting safe harbour
- how to apply the three tests
- what data can be used.
We recently published a quick reference guide on our website to provide an overview of the transitional CBC reporting safe harbour. This guide helps you understand how to apply the safe harbour and meet your obligations.
Tax consolidated groups and joint arrangements
In December, we published updated web guidance on:
- Pillar Two interactions with tax consolidated groups, including CGDMTR lodgment requirements, visit Pillar Two interactions with consolidation.
- Joint arrangements, including lodgment due dates for GloBE joint ventures, visit when and how the Pillar Two rules apply and lodging, paying and other obligations for Pillar Two.
What's next?
Our next Pillar Two information session will be held in the coming months. Subscribe to the Business bulletins newsletter to receive updates on the next session date and how to register.
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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