Check if an amendment is needed
To correct mistakes in relation to the global and domestic minimum tax, you may need to:
- amend a prior return or assessment, or
- include the correction in the current year's return.
For computational mistakes, you may need to amend one or more of your prior:
- GloBE Information Return (GIR).
- Australian IIR/UTPR tax return (AIUTR) assessment.
- Australian DMT tax return (DMTR) assessment.
If the error does not affect the amount of your top-up tax liability, you do not need to amend your assessment.
Mistakes you may need to fix include where you have:
- misclassified an item of income or tax expense
- forgotten to include an amount
- erroneously applied an exemption
- made data entry mistakes.
When you don't need to adjust or amend a return
Not all errors or adjustments require correcting a tax return. For example, you don't need to amend an assessment if the error does not affect the amount of a top-up tax liability. But you can correct a GIR for any error, not just ones which affect the top-up tax liability.
In some cases, the global and domestic minimum tax rules require adjustments to be made in the current year calculations in respect of certain errors or adjustments that relate to earlier years. In these cases, any additional top-up tax liability is reported in the current year tax return. Examples of these adjustments include those in respect of prior period accounting errors, or adjustments in respect of changes in prior period income tax liabilities.
For further details, refer to the Minimum tax lawExternal Link. You do not need to amend the prior period tax returns for these adjustments. The 4-year amendment period does not apply when making these adjustments in the current period.
For more information, see Lodging paying and other obligations for Pillar Two.
Statutory amendment period
The law sets out certain time limits for amending an assessment.
For Australian Income Inclusion Rule (IIR) tax and Australian Undertaxed Profits Rule (UTPR) tax, you must amend by the later of:
- 4 years after you, the designated local entity (DLE) or designated filing entity (DFE) have given us the multinational enterprise (MNE) group's GloBE Information Return (GIR)
- 4 years after you or your DLE have given us the Australian IIR/UTPR tax return for the relevant group entity.
For Australian DMT tax, you must amend by the later of:
- 4 years after you, the designated local entity (DLE) or designated filing entity (DFE) have given us the MNE group’s GIR
- 4 years after you or your designated local entity have given us the Australian DMT tax return for the relevant group entity.
A GIR is given to us when you or your designated local entity lodges it with the ATO electronically. For this purpose, the law also treats a GIR as being given to us at the time a foreign ultimate parent entity or designated filing entity lodges it with a foreign government agency. The following conditions must be met:
- The foreign government agency has a Qualifying Competent Authority Agreement with Australia.
- The GIR is lodged on time with the foreign agency.
- You or your designated local entity provide the ATO with a foreign lodgment notification.
For more information, see Lodging paying and other obligations for Pillar Two.
Amend a combined global and domestic minimum tax return (CGDMTR)
Amendments can only be made by the original lodging entity. For example, a DLE lodges the combined global and domestic minimum tax return (CGDMTR) on behalf of all the group entities in Australia. Subsequently, it is discovered that information in the CGDMTR relating to 2 of the group entities requires amending. In this case, only the DLE can amend the CGDMTR on behalf of these 2 group entities because it had lodged the original CGDMTR for them.
You cannot amend the following information provided in the original CGDMTR:
- Capacity of lodging entity, that is, switching from a group entity to DLE or DLE to group entity.
- Adding or removing a group entity.
- Identifiers of the lodging entity including tax file number (TFN), Australian business number (ABN), ATO reference number (ARN) and name.
- Identifiers of group entities including TFN/ABN/ARN, name and business address.
- Reporting period of the return.
All validations applicable on the original are applicable on the amendment.
After lodging the amended CGDMTR, the lodging entity will receive a lodgment success notification and a transaction ID. An amended notice of assessment (NOAA) and statement of account (SOA) (if applicable) will be issued. The relevant group entity can make a payment if a liability occurs as a result of the amendment.
Amend a GloBE Information Return (GIR)
An amendment to the GIR follows the same process as lodgment of the original GIR. Like the CGDMTR, an amendment can only be made by the original lodging entity.
The GIR XML Schema design is structured in 5 unique parts:
- FilingInfo = Part 1.1 to 1.2 of the GIR
- GeneralSection = Part 1.3 of the GIR
- Summary = Part 1.4 of the GIR
- JurisdictionSection = Part 2 and Part 3.1 to 3.4.2 of the GIR
- UTPRAttribution = Part 3.4.3 of the GIR.
When amending a GIR you must include the FilingInfo (as this is mandatory for any original lodgment and subsequent amendment). However, you only need to include the relevant part (or parts) of the GIR subsequent to the FilingInfo which are actually being amended. This means that you do no need to lodge the full GIR on an amendment, only the FilingInfo and the relevant amended part.
In amending any relevant part of the GIR, ensure to correctly complete the DocSpec Type by indicating an updated DocRefID, the correct CorrDocRefID and updating the DocTypeIndic accordingly to indicate that the relevant part is an amendment.
See GloBE Information Return (Pillar Two) XML Schema (EN)External Link (pages 126 to 128) for further guidance from the OECD.
All validation rules that are applicable on the original lodgment will likewise be applicable on the amendment.
Any amendment to the GIR will also indicate a potential new exchange of the GIR with the relevant signatories’ jurisdictions of the GIR Multilateral Competent Authority Agreement (MCAA).
The status of the amendment will follow the same process as the original lodgment. A validation report will be returned to ATO online services once the GIR has been processed by our internal systems. Allow up to 3 days for the GIR to be processed.
How to lodge an amendment
You can lodge your CGDMTR or GIR amendment using:
- Online services to business
- Online services for agents
- your third-party software packageExternal Link that supports electronic lodgment.
If you have any issues lodging electronically, contact us at Pillar2Project@ato.gov.au.