Tab 1 – Instructions
Completing information in the CGDMTR
The CGDMTR template is only intended for multinational enterprises (MNEs) that do not have the ability to lodge online. It may also need to be completed for certain transitional entity scenarios, such as where an entity transitions to another MNE group part-way through a fiscal year. If you believe this is applicable to your circumstances, contact us at Pillar2Project@ato.gov.au.
It is important that you complete all the mandatory or required fields in all the tabs on the template accurately to avoid delays in processing your tax return. We provide explanations for each question on this page to help you complete the sections correctly.
Who needs to complete the CGDMTR?
In-scope multinational enterprise groups (MNE groups) need to complete the Combined global and domestic minimum tax return (CGDMTR) template.
An in-scope MNE group is one whose annual revenue, as shown in the consolidated financial statements of the ultimate parent entity (UPE), equals or exceeds 750 million euros in at least 2 of the 4 fiscal years preceding the test year. You should consider how the law applies to your particular circumstances.
The Australian global and domestic minimum tax implements the OECD Global Anti-Base Erosion Model RulesExternal Link (GloBE Rules). It was enacted through primary and subordinate legislation, referred to together as the Minimum Tax law.
The Minimum Tax law contains lodgment requirements for in-scope MNE groups.
For further details, see When and how the Pillar Two rules apply.
Excluded entities
Certain entities of an MNE group are excluded from the operation of the Minimum Tax law (known as GloBE excluded entities). As an excluded entity, you do not have a lodgment obligation. See who the rules apply to.
Exempted entities
Entities may be exempt from the requirement to lodge one or both of the Australian Income Inclusion Rule (IIR) and Undertaxed Profits Rule (UTPR) Tax Return (AIUTR) and Domestic Minimum Tax Return (DMTR) under the Legislative instrument.
Where an entity is exempt from lodging an AIUTR or DMTR, or both the AIUTR and DMTR, the CGDMTR would be lodged only for the applicable component(s) in respect of that entity. For example, if an entity is exempt from lodging the AIUTR but not the DMTR, you would:
- proceed with completing details of the DMTR and foreign lodgment notification (if required)
- select 'No' to the sections that relate to the AIUTR.
You should review the application of the law to your own circumstances to determine if you have a lodgment obligation.
What to lodge
Depending on your circumstances, you may be required to lodge a:
- foreign lodgment notification
- AIUTR
- DMTR.
To simplify lodgment, all 3 lodgment obligations are contained within the CGDMTR template.
For further details about lodging obligations (and the CGDMTR), see Lodging, paying and other obligations for Pillar Two. This includes information regarding how obligations apply to:
- GloBE permanent establishments
- GloBE joint ventures
- GloBE partnerships
- trusts
- other unincorporated group entities.
Currency
Any amount disclosed in the CGDMTR needs to be reported in Australian dollars (AUD).
Foreign exchange conversion for top-up tax amounts
Australian top-up tax amounts in the CGDMTR must be disclosed in AUD, including:
7B: Australian domestic top-up tax amount
7D: Australian IIR top-up tax amount
If the top‑up tax amount is nil, you still lodge (nil), but there is no conversion to perform.
Step 1: Identify the amounts denominated in a foreign currency
This will be any top-up tax amount (greater than nil) calculated in the reporting currency of the consolidated financial statements of the UPE that result in Australian top-up tax.
Step 2: Convert amounts to AUD using an approved year-end exchange rate
To convert from a foreign currency into AUD, use the exchange rate on the last day of the fiscal year from one of these permitted sources:
Reserve Bank of Australia (RBA) daily rate
the central bank for the foreign currency
a publicly and commercially available market rate.
Step 3: Record keeping
Keep evidence of the top‑up tax amount being disclosed, the FX source you selected, the exchange rate used, and your calculation.
For further information on refer to section 1-25 of the Australian Minimum Tax Rules.
Record-keeping requirements
The Minimum tax law introduces new record-keeping requirements in respect of the Australian global and domestic minimum tax.
Privacy
Our ATO privacy policy contains important information about your privacy, including how:
- you can access and seek correction of information we hold about you
- you may complain about a breach of the Australian Privacy Principles
- we will deal with any privacy complaint.
See further information at:
- Privacy notice – Combined global and domestic minimum tax return
- What to do about a suspected breach of privacy.
You can contact us:
- using our online complaints form
- by phoning 1800 199 010
- by mail to
- ATO COMPLAINTS
PO BOX 1271
ALBURY NSW 2640
- ATO COMPLAINTS
Lodging electronically
The CGDMTR must be lodged electronically.
The CGDMTR template, once completed, must be lodged via ATO's secure file sharing platform as outlined below.
The quickest and easiest way to lodge electronically is by using Online services for business or your tax agent can lodge the CGDMTR via Online services for agents.
Alternatively, you may lodge using a third party developed software package that supports electronic lodgment.
The CGDMTR template should only be used as a last resort, where the above channels are not applicable and where you meet the requisite eligibility for lodgment via the CGDMTR template channel.
If lodging the CGDMTR template electronically, you must:
- Adhere to the template limit of 300 group entities, including the lodging entity.
- Submit this file in .xls or .xlsx (Microsoft Excel) format only. Do not convert this file to a PDF.
- Do not add additional columns, formulas or macros into this file. Modified templates will be rejected.
- Ensure all mandatory or required fields are completed. Fields marked with an asterisk (*) are mandatory.
- Fields marked with a hashtag (#) requires one identifier in that section to be selected.
- Save the file in this format: CGDMTR 2024 - <name of the lodging entity> (for example, CGDMTR 2024 – 123 PTY LTD).
- Submit the completed form through our secure file sharing (SFS) platform. Our current SFS service provider is Kiteworks. We will provide you with instructions on sending the completed form via Kiteworks.
Note: If you are not sure whether you need to lodge a tax return, see Lodging, paying and other obligations for Pillar Two.
Lodgment due dates
The GIR (where the GIR is being lodged in Australia), foreign lodgment notification, AIUTR and DMTR are required to be lodged by the due date.
For the first fiscal year of the measure, the lodgment due date is 18 months after year end.
For the second and subsequent fiscal years, the lodgment due date is 15 months after year end.
Lodgment due date for the first fiscal year
- Example 1: December balancer
- Year-end date: Fiscal year ending 31 December 2024
- Lodgment due date: 30 June 2026
- Example 3: June balancer
- Year-end date: Fiscal year ending 30 June 2025
- Lodgment due date: 31 December 2026
Lodgment due date for subsequent fiscal years
- Example 2: December balancer
- Year-end date: Fiscal year ending 31 December 2025
- Lodgment due date: 31 March 2027
- Example 4: June balancer
- Year-end date: Fiscal year ending 30 June 2026
- Lodgment due date: 30 September 2027
As the lodgment due date depends on your fiscal year end, make sure to check the specific due date that applies to your MNE group.
If a due date falls on a weekend or public holiday, you can lodge or pay on the next business day.
Assessment
Top-up tax is self-assessed. In general, the Commissioner of Taxation will be deemed to have made an assessment on the day on which an AIUTR or DMTR, contained in the CGDMTR, is lodged, in respect of each return and each entity covered by the lodgment.
An entity will not generally receive a separate notice of assessment. The lodged return is itself treated as a notice of assessment under law. However, we will issue a notice of amended assessment if subsequent amendments are made.
The Commissioner can make a default assessment of top-up tax amounts if a group entity fails to lodge or provide sufficient information in its return.
Payment
Your payment needs to reach us on or before its due date, regardless of whether the payment is made in Australia or from overseas. The amount is due and payable:
- on the last day of the 18th month after the end of the fiscal year for the first year of the measure
- on the last day of the 15th month after the end of the fiscal year for subsequent years of the measure.
Payment methods
We offer a range of payment options, both in Australia and overseas. Our preferred payment methods are:
- BPAY®
- credit or debit card.
For more payment options, see How to pay.
You need to quote your payment reference number (PRN) when making a payment. It is important that you provide the correct PRN.
If you are unable to locate your PRN, you can:
- find your PRN on your Online services for business account, or your tax agent can access it via Online services for agents
- phone us on 1800 815 886, 8.00 am to 6.00 pm, Monday to Friday
- email us at payment@ato.gov.au.
On completion of your CGDMTR, you will be provided with a PRN for each entity that has an amount payable. This number:
- will be shown on the confirmation page if lodging via online services
- is unique to each entity and must be used to make payment with each PRN corresponding to the relevant entity.
What if a group entity cannot pay its tax debt by the due date?
Each group entity is expected to organise its affairs to ensure debts are paid on time. However, depending on the circumstances you may be able to enter into a payment plan arrangement to pay by instalments.
You may need to provide details of the group entity’s financial position, including:
- a statement of its assets and liabilities
- details of its income and expenditure.
We will also want to know:
- what steps you have taken to obtain funds to pay the tax debt
- the steps you are taking to meet future payments of tax debts on time.
For more information if you cannot pay the debt on time, contact us.
Penalties and interest charges
The existing uniform penalty provisions will apply to obligations under the Minimum Tax law. However, the Organisation for Economic Co-operation and Development (OECD) has released guidance on transitional penalty relief, which asks that administrators consider providing a soft landing for MNE groups during a transition period.
Accordingly, we have published Practical Compliance Guideline PCG 2025/4 Global and domestic minimum tax lodgment obligations – transitional approach, which outlines:
- our approach to the enforcement of penalties during a transition period
- expectations in respect of lodgment obligations for the global and domestic minimum tax.
See further details about penalties.
Tab 2 – Lodging entity information
Instructions for completing Tab 2 of the CGDMTR 2024 template.
Before you start
When we say 'you' or 'the lodging entity' in this section of the instructions, we mean you as either the standalone group entity or as a designated local entity (DLE).
For a DLE lodging the CGDMTR template on behalf of group entities, the ATO template will support Combined global and domestic minimum tax return (CGDMTR) lodgments for up to 300 entities.
A group entity that does not have a lodgment obligation is not counted towards the 300 entity limits. If you are a DLE lodging on behalf of more than 300 entities, contact us at Pillar2Project@ato.gov.au.
Section 1: Reporting fiscal year
This field is mandatory.
Reporting fiscal year – standard 12 month
Enter the fiscal year this CGDMTR covers in the format DD/MM/YYYY. The fiscal year start and end dates must reflect the first and last day of the month, for example, 1 January to 31 December.
The fiscal year generally aligns with the accounting period used by your ultimate parent entity when it prepares its consolidated financial statements. The fiscal year may differ from your income tax year.
If your fiscal year is shorter or longer than 12 months, contact us at Pillar2Project@ato.gov.au to discuss lodgment.
Reporting fiscal year – transitioning entity
If an entity leaves an applicable multinational enterprise group (MNE group) and joins another applicable MNE group partway through the fiscal year, the transitioning entity may have separate Australian lodgment obligations for each group, for the fiscal year in which the transfer occurs.
It is important you contact us at Pillar2Project@ato.gov.au before lodgment if you have a transitioning entity. We will need to tell you how to lodge for that entity to ensure its lodgments can be accepted by our systems.
For more information on circumstances where you do not need to contact us, refer to Lodging, paying and other obligations for Pillar Two.
Section 2: Lodging entity information
This field is mandatory. You must select a label.
Determine whether you are lodging as a standalone group entity or as the DLE.
Indicate by selecting the appropriate description. If you are lodging as a
- 2A: group entity, you are lodging as a standalone entity. For the purpose of this form, a group entity includes the GloBE joint venture and GloBE joint venture subsidiaries.
- 2B: DLE, you are the entity appointed by all other group entities to lodge the CGDMTR on their behalf.
Lodging capacity for the CGDMTR cannot be amended once submitted for a fiscal year, so if you lodge as:
- a group entity, you cannot amend the CGDMTR to change lodging capacity to a DLE
- the DLE, you cannot amend the CGDMTR to change the lodging capacity to a group entity.
For more information, see Lodging, paying and other obligations for Pillar Two.
Section 3: Designated local entity or group entity identification details
3A: Name of the entity
This field is mandatory.
Enter the legal or registered name of the DLE or group entity lodging this return.
For subsequent tax returns, ensure the entity’s name is consistent from year to year unless the name changes. If the entity’s legal name has changed, notify us at the time the change is made.
How to update entity details
You can update the entity’s details:
- online – through the Australian Business RegisterExternal Link or Online services for business. Note that clients with an ATO reference number (ARN) are not eligible to access Online services for business, which is only available to Australian business number (ABN) holders. Clients with an ARN will need to update their details by phoning us on 13 28 66.
- by phone – if you're an authorised contact for the entity, phone us on the business enquiries line on 13 28 66 (not applicable for adding or updating public officer details).
- by lodging a form – order the Change of registration details form (NAT 2943) using our publication ordering service. This is available to trusts, partnerships and companies.
- through your registered tax agent.
Lodging entity identifier
Provide at least one client identifier for the lodging entity (3B-3E). You do not need to complete all 4 identifiers. To assist with linking the group’s information with our systems information, we ask that you provide at least one primary identifier being either your TFN or ABN, or both.
The tax identification number (TIN) or ARN should only be entered if the lodging entity is not eligible to have a tax file number (TFN) or ABN.
One identifier in this section is required as mandatory.
Primary identifiers
- 3B: Tax file number (TFN) – enter the TFN of the lodging entity in the space provided. You do not need to quote your TFN, however there may be delays in processing the CGDMTR if lodged without a TFN.
- 3C: Australian business number (ABN) – enter the ABN of the lodging entity in the space provided if the lodging entity is registered on the Australian Business RegisterExternal Link (ABR).
Secondary identifiers
- 3D: ATO reference number (ARN) – enter the ARN of the lodging entity in the space provided.
- 3E: Tax identification number (TIN) – enter the TIN of the lodging entity in the space provided, as disclosed on the GIR.
Section 4-1: Authorised contact details for the designated local entity or group entity
Complete details of the designated local entity’s or group entity’s authorised contact information.
All fields in this section are mandatory.
We may need additional information for example, if your trustee is a company then we need details of the company's authorised contact, in case we need to discuss aspects of this return. Provide the following information:
- 4A: Contact name – enter the full name of the authorised contact. Ensure you have updated the details of the authorised contact for your Minimum Tax obligations.
Phone number
- 4B1: Country code – include the country code for an international number if an Australian phone number is not available, otherwise add '61' for Australia. Do not include a '+' (plus) sign.
- 4B2: Phone number (including area code) – enter a phone number of the authorised contact that we can contact during business hours including the area code. Do not include '()' (bracket) signs around the area code.
- 4O: Email address – provide an email address. Ensure you have updated the details of your email address for your global and domestic minimum tax obligations.
Section 4-2: Address details for the designated local entity or group entity
Complete details of the DLE's or group entity’s address information. An overseas address should only be provided if there is no applicable address in Australia for the entity.
All fields in this section are mandatory.
Postal address
- 4C-4D: Postal address – enter the current postal address of the lodging entity. If the lodging entity does not have a postal address, enter the postal address of the UPE. Use C/- when ‘care of’ is part of an address – it is the only acceptable format. Using any other term will delay the processing of the CGDMTR. Correspondence will be issued to the listed postal address.
- 4E: Suburb/Place/Locality – enter the suburb, place, or locality of the postal address.
- 4F: Postcode – enter the current postcode of the postal address.
- 4G: State/Territory – enter the state or territory of the postal address.
- 4H: Country – select the country of the postal address.
Business address
- 4I-4J: Business address – enter the current Australian business street address of the lodging entity. Provide an overseas address only if there is no applicable Australian address for the entity.
- 4K: Suburb/Place/Locality – enter the suburb, place or locality of the street address.
- 4L: Postcode – enter the current postcode of the street address.
- 4M: State/Territory – enter the state or territory of the street address.
- 4N: Country – enter the country of the street address.
Section 5-1: Lodging entity type
5A: Lodging entity type
Your entity type for global and domestic minimum tax purposes may differ to your entity type for income tax purposes. Learn more about who the rules apply to and how they apply for different entity types.
It is mandatory to select an entity type for Label 5A from the drop-down menu:
- Company
- Trust
- GloBE partnership
- Main entity of a GloBE permanent establishment that is a company
- Main entity of a GloBE permanent establishment that is not a company
- GloBE joint venture
- Unincorporated GloBE joint venture that is a GloBE partnership
- Unincorporated GloBE joint venture that is not a trust nor a GloBE partnership
- Unincorporated GloBE joint venture subsidiary where the subsidiary is a GloBE partnership
- Unincorporated GloBE joint venture subsidiary where the subsidiary is not a trust nor a GloBE partnership
- Unincorporated group entity that is not a trust nor a GloBE partnership.
If you fall into 2 categories, you should choose the option which reflects your primary classification under the Minimum Tax law. For example, if you are completing the return as a company and are also classified as a GloBE joint venture, choose the GloBE joint venture option.
For more information, refer to Table 1: Description of entity type.
Go to Section 6 if 5A Lodging entity type is a:
- Company
- Main entity of a GloBE permanent establishment that is a company
- GloBE joint venture.
Otherwise, continue with 5-2 Associate entity details.
Section 5-2: Associate entity details
Do not complete Section 5-2 and go to Section 6 if 5A Lodging entity type is either a:
- Company
- Main entity of a GloBE permanent establishment that is a company
- GloBE joint venture.
For the purpose of the CGDMTR a reference to an ‘associate entity’ refers to the main entity for those instances where the lodging entity is not a separate legal person. For example, in the case of a trust this would be the trustee.
In the CGDMTR you will need to provide your details and, if required, the associate entity details that correspond to the selected entity type. Your information will need to be entered in Tab 2 Lodging entity information. In this section, enter the associate entity’s details.
An associate entity can be:
- a trustee of a trust
- the main partners of the partnership
- the joint venture owner
- the joint venture partner
- an authorised contact of a joint operation.
All fields in Section 5-2 are mandatory except for 5C: Tax file number (TFN).
- 5B: Associate entity name – provide the full name of the associate entity corresponding to the selected entity type
- 5C: Associate entity TFN – enter the TFN of the associate entity in the space provided. You don't need to quote the TFN. However, there may be delays in processing the CGDMTR if lodged without a TFN.
Phone number
- 5D1: Country code – include the country code for an international number, otherwise add '61' for Australian phone number. Do not include a '+' (plus) sign.
- 5D2: Phone number (including area code) – enter the phone number of the associate entity including area code. Do not include '()' (bracket) signs around the area code.
Postal address
- 5E-5F: Address – enter the current postal address of the associate entity. Use C/- when ‘care of’ is part of an address, it is the only acceptable format. Using any other term will delay the processing of the CGDMTR.
- 5G: Suburb/Place/Locality – enter the suburb, place or locality of the postal address.
- 5H: Postcode – enter the current postcode of the postal address.
- 5I: State/Territory – enter the state or territory of the postal address.
- 5J: Country – enter the country of the postal address.
Tab 3 – Combined return details
Instructions for completing Tab 3 of the CGDMTR 2024 template.
This tab requires:
- information about each group entity (including the lodging entity), similar to details requested in Tab 2
- an indication of whether a foreign lodgment notification is or will be lodged for each group entity
- amounts payable.
This tab does not require information about where the GIR is lodged - this information is captured in Tab 4 – Foreign lodgment notification.
Section 6 and Section 7 are combined and set out as a table.
Note: The undertaxed profits rule (UTPR) does not apply until fiscal year starting 1 January 2025. For more information, see Pillar Two implementation in Australia.
Section 6: Group entities and combined return details
This is your entity type for global and domestic minimum tax purposes. This may differ to your entity type for income tax purposes.
If you are lodging as a standalone entity, you are only required to complete your own details.
If you are lodging as a DLE, you:
- must complete an entry for each group entity you are lodging on behalf of
- should review the Legislative Instrument, as it may not require an entity to be listed here
- will need to indicate which reporting obligations apply to each entity
- must report any applicable
- Foreign lodgment notification
- IIR top-up tax amount, including a nil amount.
- Australian DMT tax amount, including a nil amount.
Note: The UTPR does not apply until fiscal year starting 1 January 2025.
When reporting for entities in your MNE group:
- Depending on your circumstances, you may not need to report every entity within the MNE group. Refer to Lodging, paying and other Pillar Two obligations and our legislative instrument for further details regarding your lodgment obligations.
- Don't not include entities with a different fiscal year, such as when an entity has joined or left your MNE group during the fiscal year. The relevant entity will need to lodge separately.
- If you are lodging for more than 300 entities, contact the Pillar Two Project Team at pillar2project@ato.gov.au.
Client identifiers
Complete details for at least one of the following client identifiers (only enter an ARN when a TFN or ABN cannot be provided). Don't complete all 3 identifiers. The ARN should only be entered if the group entity does not have a TFN or ABN.
For more information on client identifiers and how they are used in the CGDMTR, refer to Lodging entity identifiers in Section 3: Designated local entity or Group entity identification details.
- 6A: Tax file number (TFN) – enter the TFN of the group entity in the space provided. You don't need to quote your TFN. However, there may be delays in processing the CGDMTR if lodged without a TFN.
- 6B: Australian business number (ABN) – enter the ABN of the group entity in the space provided if the group entity is registered on the Australian Business RegisterExternal Link (ABR).
- 6C: ATO reference number (ARN) – enter the ARN of the group entity in the space provided.
Entity details
- 6D: Name of the entity – this is a mandatory field. Enter the legal or registered name of the group entity. For further information, refer to 'Name of the entity' in Section 3: Designated local entity or Group entity identification details.
- 6E-6F: Business address – this is a mandatory field. Enter the current Australian business address of the group entity. Provide an overseas address only if there is no applicable Australian address for the entity.
- 6G: Suburb/Place/Locality – enter the suburb, place or locality of the street address.
- 6H: State/Territory – enter the state or territory of the street address.
- 6I: Country – enter the country of the street address.
- 6J: Postcode – enter the current postcode of the street address.
Entity type
- 6K: Entity type – this is a mandatory field. Use the drop-down menu and make your selection. Refer to Section 5-1: Lodging entity type for further information. Go to 6U if 6K Entity type is either a:
- company
- main entity of a GloBE permanent establishment that is a company
- GloBE joint venture
Otherwise, continue with 6L
Associate entity details
Refer to Section 5-2: Associate entity details for further information.
Fields 6L-6T are only mandatory depending on your selection at field 6K. Quoting your TFN at field 6M is not mandatory.
- 6L: Associate entity name – provide the full name of the associate entity corresponding to the selected entity type.
- 6M: Associate entity TFN – enter the TFN of the associate entity in the space provided. You don't need to quote the TFN. However, there may be delays in processing the CGDMTR if lodged without a TFN.
- 6N: Associate entity phone number (including area code) – enter the phone number of the associate entity including area code. Do not include '()' (bracket) signs around the area code.
- 6O-6P: Associate entity postal address – enter the current postal address of the associate entity. Use C/- when ‘care of’ is part of an address, it is the only acceptable format. Using any other term will delay the processing of the CGDMTR.
- 6Q: Associate entity Suburb/Place/Locality – enter the suburb, place or locality of the postal address.
- 6R: Associate entity State/Territory – enter the state or territory of the postal address.
- 6S: Associate entity Country – enter the country of the postal address.
- 6T: Associate entity Postcode – enter the current postcode of the postal address.
Combined lodgment information
- 6U: Are you lodging a foreign lodgment notification for this entity? – this field is mandatory. Select 'Yes' or 'No' from the drop-down menu. If you select 'No' at 6U, you are confirming the GIR is lodged or will be lodged in Australia.
|
Option |
Description |
Foreign lodgment notification required? |
|---|---|---|
|
GIR lodged overseas |
The MNE group appoints either the UPE or designated filing entity (DFE) to lodge the GIR in a foreign jurisdiction. The UPE or DFE must be located in a jurisdiction which has an activated exchange relationship for the automatic exchange of the GIR. See the list of jurisdictions with a GIR MCAA or equivalent agreement with AustraliaExternal Link |
Yes Must notify the ATO of the UPE or DFE information |
|
GIR lodged in Australia (standalone) |
Each group entity lodges the GIR with the ATO separately. Where no operative GIR MCAA or equivalent agreement exists between Australia and the UPE or DFE jurisdiction, the lodging entity must lodge the GIR with the ATO. |
No |
|
GIR lodged in Australia (DLE) |
The DLE lodges the GIR with the ATO. |
No |
Continue with Australian DMT tax return and IIR/UTPR tax return for this entity?
6V: Are you lodging an Australian IIR/UTPR tax return and Australian DMT tax return for this entity? – this field is mandatory. Select 'Yes' or 'No' from the drop-down menu. Top-up tax amounts at 7A to 7E is mandatory if you select 'Yes' at 6V.
Not sure whether to select Yes or No?
There is a default obligation on all group entities to lodge an AIUTR and DMTR, even when the entity has a nil amount. However, the Commissioner of Taxation, by legislative instrument, has specified the circumstances in which a group entity is exempt from lodging an AIUTR or a DMTR for a fiscal year. For more information on which group entities are exempt, see Legislative Instrument LI 2025/28.
Note: you do not have to list details of excluded entities.
For further information, refer to Global and domestic minimum tax.
Section 7: Australian DMT tax return and Australian IIR/UTPR tax return
If you have an obligation to lodge, but any top-up tax amounts are nil, select 'Yes' and enter a zero value (0). For details of when you have to lodge, see Lodging, paying and other obligations for Pillar Two.
Note: Australian undertaxed profits rule (UTPR) will apply for fiscal years starting on or after 1 January 2025.
- 7A: Is this entity required to report an Australian domestic top-up tax amount (including a nil amount)?
- Select 'Yes' at 7A if the entity is required to lodge a DMTR for the fiscal year in respect of the MNE group. Enter the total of the entity's domestic top-up tax amounts, including a nil amount at 7B. The sum of these amounts is an amount of Australian DMT tax, being tax payable under section 8 of the Taxation (Multinational–Global and Domestic Minimum Tax) Act 2024 (Minimum Tax Act).
- Select 'No' at 7A if the entity is an excluded entity or it is exempt from lodging a DMTR. For more information, see LI 2025/28.
- 7C: Is this entity required to report an Australian IIR top-up tax amount (including a nil amount)?
- Select 'Yes' at 7C if the entity is required to lodge an AIUTR for the fiscal year in respect of the MNE group. Enter the total of the entity's IIR top-up tax amounts, including a nil amount at 7D. The sum of these amounts is an amount of Australian IIR tax, being tax payable under section 6 of the Minimum Tax Act.
- However, you can choose to select No even if the entity is required to lodge an AIUTR, if the entity's circumstances are described in paragraph 11(1)(a) of the legislative instrument. Those paragraphs describe circumstances in which an entity could never have an IIR top-up tax amount greater than nil. In these cases, you can either choose to select 'No' or report a nil amount at this item.
- 7E: Select the appropriate parent entity type from the drop-down menu. See Table 3: Parent entity types below.
- Select 'No' if the entity is an excluded entity or it is exempt from lodging an AIUTR. For more information about lodgment exemptions, see LI 2025/28.
|
Parent entity type |
Definition |
|---|---|
|
Ultimate parent entity (UPE) |
UPE means either:
|
|
Intermediate parent entity (IPE) |
A group entity (other than an ultimate parent entity, partially owned parent entity, permanent establishment, or investment entity) that owns (directly or indirectly) an ownership interest in another group entity in the same MNE group. |
|
Partially owned parent entity (POPE) |
A group entity of an MNE group (other than an ultimate parent entity, parent entity, investment entity or insurance investment entity):
|
Tab 4 – Foreign lodgment notification
Instructions for completing Tab 4 of the CGDMTR 2024 template.
Local and foreign GIR lodgment notification
All lodging entities must complete this section to disclose the following information:
- UPE details
- GIR lodgment details
- Foreign lodgment notification
- GIR details: foreign exchange rate.
Section 8: Ultimate parent entity (UPE) details
- 8A: Is the designated local entity or the group entity who is lodging this return the same as the UPE? This field is mandatory.
- If you select 'No', then continue.
- If you select 'Yes', you are the UPE and no further information is required. This information will match the information provided in the GIR. Move to Section 9. This field is mandatory.
When the lodging entity is not the UPE of the MNE group, we ask that you provide details for the UPE of the MNE group in the remaining fields in Section 8.
- 8B: Name of the UPE – enter the name of the UPE exactly as reported in the GIR. This field is mandatory if you selected 'No' at 8A.
Client identifiers
Complete details for at least one of the following client identifiers for the UPE. However, providing more than one identifier will allow us to link with your existing details (only enter a TIN when a TFN or ABN cannot be provided).
For more information on client identifiers and how they are used in the CGDMTR, refer to Section 3: Lodging entity identifiers.
- 8C: Tax file number (TFN) – Enter the TFN of the UPE in the space provided. You do not need to quote the UPE's TFN. If you do not quote the TFN, you must quote the ABN or TIN of the UPE.
- 8D: Australian business number (ABN) – If the UPE is registered on the Australian Business RegisterExternal Link (ABR), enter the ABN of the UPE.
- 8E: Tax identification number (TIN) – If the UPE does not have a TFN or ABN, enter the TIN as it appears in the GIR. If the UPE is located in a jurisdiction other than Australia, enter only the TIN issued to the UPE in that jurisdiction. The TIN may have different names in other jurisdictions.
Postal address
All fields in the postal address are mandatory if you selected 'No' at 8A.
- 8F-8G: Postal address – enter the current postal address of the UPE. Use C/- when ‘care of’ is part of an address, it is the only acceptable format. Using any other term will delay the processing of the CGDMTR. This will match with the address provided in the GIR.
- 8H: Suburb/Place/Locality – enter the suburb, place or locality of the postal address.
- 8I: State/Territory – enter the state or territory of the postal address.
- 8J: Country – enter the country of the postal address.
- 8K: Postcode – enter the current postcode of the postal address.
- 8L: Jurisdiction where the UPE is located – select from the drop-down menu the jurisdiction where the UPE is located. This will match with the UPE jurisdiction provided in the GIR.
Section 9: GIR lodgment details
This section must be completed to inform the ATO of the jurisdiction and date the GIR was lodged in Australia.
- 9A: Where is the GIR lodged or will be lodged? – identify the jurisdiction in which the GIR for the group entity/ies identified in Section 6: Group entities and combined return details has been or will be lodged. Select one of the following options from the drop-down menu:
- GIR is lodged or will be lodged in Australia
- GIR is lodged or will be lodged by UPE in a foreign jurisdiction
- GIR is lodged or will be lodged by DFE in a foreign jurisdiction.
Option 1: GIR is lodged or will it be lodged in Australia?
No By selecting this option, you confirm that the GIR is lodged, or will be lodged, in a foreign jurisdiction.
Yes By selecting this option, you confirm that the GIR will be lodged directly with the ATO, and not through a foreign tax authority. Continue to 9B and complete GIR lodgment date. Once completed move to Section 11.
Option 2: GIR is or will be lodged by the UPE in a foreign jurisdiction?
- No If this option is selected, select Option 3.
- Yes By selecting this option, you confirm that the GIR has been lodged, or will be lodged, by a foreign UPE in the jurisdiction in which it is located.
You must complete a foreign lodgment notification. This will be used to inform the ATO whether the GIR has been or will be lodged in a jurisdiction that has a GIR MCAA or equivalent agreement.
Section 10-1: Foreign lodgment notification (UPE)
- 9C: Will the ATO receive the GIR from the UPE jurisdiction under Exchange of Information? Select 'Yes' or 'No'.
- 9D GIR lodgment date. Once completed go to Section 11.
(3) GIR is lodged or will it be lodged by the DFE in a foreign jurisdiction?
- No 'No' cannot be selected in this context. This indicates an error. Review Steps 1 and 2 to confirm whether the GIR is being lodged in Australia or in a foreign jurisdiction.
- Yes By selecting this option, you confirm that the GIR has been lodged, or will be lodged, by a foreign DFE in the jurisdiction in which it is located.
You must complete a foreign lodgment notification. This will be used to inform the ATO whether the GIR has been or will be lodged in a jurisdiction that has a GIR MCAA or equivalent agreement.
You must also complete the details of the DFE. Go to Section 10-2 Foreign lodgment notification (DFE).
Section 10-2: Foreign lodgment notification (DFE)
- 10A: Name of the DFE – enter the name of the DFE exactly as reported in the GIR. This field is mandatory if you selected 'By DFE in a foreign jurisdiction' at Label 9A.
Client identifiers
Complete details for at least one of the following client identifiers for the DFE. Don't complete all 3 identifiers. The TIN should only be entered if the DFE does not have a TFN or ABN.
Refer to Section 2: Lodging entity information for more information on client identifiers and how they are used in the CGDMTR.
- 10B: Tax file number (TFN) – enter the TFN of the DFE in the space provided. You do not need to quote your DFE's TFN. If you do not quote the TFN, you must quote an ABN or the TIN of the DFE.
- 10C: Australian business number (ABN) – if the DFE is registered on the Australian Business RegisterExternal Link (ABR), enter the ABN of the DFE.
- 10D: Tax identification number (TIN) in the jurisdiction that the DFE is located – if the DFE does not have a TFN or ABN, enter the TIN as it appears in the GIR. If the UPE is located in a country other than Australia, enter only the TIN issued to you in that country. The TIN may have different names in other jurisdictions.
Postal address
All fields in the postal address are mandatory if you selected By DFE in a foreign jurisdiction at label 9A.
- 10E-10F: Postal address – enter the current postal address of the DFE. Use C/- when ‘care of’ is part of an address, it is the only acceptable format. Using any other term will delay the processing of the CGDMTR.
- 10G: Suburb/Place/Locality – enter the suburb, place or locality of the postal address.
- 10H: State/Territory – enter the state or territory of the postal address.
- 10I: Country – enter the country of the postal address.
- 10J: Postcode – enter the current postcode of the postal address.
Jurisdiction of the DFE
All fields are mandatory if you selected By DFE in a foreign jurisdiction at Label 9A.
- 10K: Jurisdiction where the DFE is located – select from the drop-down menu the country for the jurisdiction where the DFE is located.
A valid foreign lodgment notification is one that notifies us that a foreign DFE has lodged, or will lodge, the GIR in its foreign jurisdiction.
See Automatic exchange of GloBE informationExternal Link to determine if the jurisdiction has such an agreement.
- 10L: Will the ATO receive the GIR from the DFE jurisdiction under Exchange of Information? Select from the drop-down menu.
- Select 'No' if the GIR is lodged in a foreign jurisdiction without a GIR MCAAExternal Link or equivalent agreement. A GIR must be lodged directly with us if 'No' is selected.
- Select 'Yes' if the GIR is lodged in a foreign jurisdiction with a GIR MCAAExternal Link or equivalent agreement.
- 10M: GIR lodgment date – provide the date the GIR was lodged by the DFE. If the GIR has not yet been lodged, provide the expected lodgment date.
Additional information regarding GIR lodgment date
For those lodging in a foreign jurisdiction, this information assists the ATO in following up with the foreign government agency for the portion of the GIR required to be exchanged with Australia.
If the GIR has been lodged but the lodgment date is unknown, refer to the ‘TIMESTAMP’ element in the message header of the GIR XML. The ‘TIMESTAMP’ element identifies the date and time when the GIR XML was prepared and sent.
Don't enter the expected exchange with the ATO. Only provide the lodgment date in the foreign jurisdiction.
If the UPE or DFE lodges the GIR with the foreign government agency after the due date specified in Australia's legislation, each Australian group entity will not be treated as having lodged the GIR in Australia at the time of foreign lodgment and their Australian GIR lodgment obligations will remain unsatisfied. In that case, group entities will be taken to have lodged the GIR at the time we receive it from the foreign government agency on exchange or at the time it is otherwise lodged directly with us. We may require the GIR to be lodged locally before the GIR is exchanged with us.
Section 11: GIR details – foreign exchange rate
Complete these mandatory labels where any of the group entities reported at Section 6 and Section 7 have a top-up tax amount greater than nil (0).
Australian top-up taxes include Australian IIR and Australian UTPR and Australian domestic top-up tax amounts.
- 11A: Currency used in the GIR for Australian top-up taxes – select the 3-letter currency code that corresponds to the currency used in the GIR.
- 11B: Exchange rate used to convert from foreign currency to AUD for Australian top-up taxes – report the foreign exchange rate used to convert foreign currency to AUD for Australian top-up taxes. See currency to determine what exchange rates can be used.
- 11C: Methodology used to convert Australian top-up taxes from another currency to AUD – report the methodology used to convert Australian top-up taxes from another currency to AUD.
When computing the amounts relevant for the computation of the domestic top-up tax amount, the applicable currency to be used is AUD unless an election has been made by the lodging entity that specifies a different currency.
An applicable MNE group may only make an election to specify a currency other than AUD where one or more Australian entities do not use AUD as their functional currency. The election is a 5-year election and may be applied to begin in a specified fiscal year. The election must specify whether the applicable MNE group will use AUD or the currency used in the consolidated financial statements of the UPE of the applicable MNE group.
Tab 5 – Declarations
There are 3 options under the Declarations tab. Select the appropriate declaration, complete the checkboxes and date the declaration. Only complete one Declaration.
Before signing, refer to our Privacy notice – Combined Global and Domestic Minimum tax return.
Section 12: Declaration (for the group entity)
Ensure only one of the two check boxes is selected, and date is provided.
Before making this Declaration, check to ensure that all top-up tax amounts have been disclosed and the tax return is true and correct in every detail. If you are in doubt about any aspect of the tax return, place all the facts before the ATO. The tax laws impose heavy penalties for false or misleading statements in tax returns.
This Declaration must be signed by an authorised contact of the DLE or the DLE’s public officer. However, if completing this form as a group entity, the group entity’s authorised contact or public officer must sign this declaration. 'Group entity' for the purpose of this form includes GloBE joint ventures and GloBE JV subsidiaries.
Section 12: Declaration (for the DLE)
Ensure all check boxes are selected, and date is provided.
Before making this Declaration, check to ensure that all top-up tax amounts have been disclosed, and the tax return is true and correct in every detail. If you are in doubt about any aspect of the tax return, place all the facts before the ATO. The tax laws impose heavy penalties for false or misleading statements in tax returns.
This Declaration must be signed by an authorised contact of the DLE or the DLE’s public officer. However, if completing this form as a group entity, the group entity’s authorised contact or public officer must sign this declaration. 'Group entity' for the purpose of this form includes GloBE joint ventures and GloBE JV subsidiaries.
Section 12: Declaration (for tax agents)
Ensure all check boxes are selected and that all required details are provided.
Before making this Declaration ,check to ensure that all top-up tax amounts have been disclosed, and the tax return is true and correct in every detail. If you are in doubt about any aspect of the tax return, place all the facts before the ATO. The tax laws impose heavy penalties for false or misleading statements in tax returns.
This Declaration must be signed by an authorised contact of the DLE or the DLE’s public officer. However, if completing this form as a group entity, the group entity’s authorised contact or public officer must sign this declaration. 'Group entity' for the purpose of this form includes GloBE joint ventures and GloBE JV subsidiaries.