About the CGDMTR

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) online form.

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 online form.

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.

Get the CGDMTR

You can access the CGDMTR through Online services for business, or your tax agent can access the CGDMTR via Online services for agents.

For instructions on how to register for ATO online services, see:

Get the CGDMTR instructions

For help preparing the CGDMTR, see the CGDMTR instructions.

You can create and save a PDF copy of the instructions from this page – select the Print or Download icon under the page heading, then select PDF whole topic.

These instructions will help you to complete the CGDMTR. They are not a guide to the Minimum Tax law. The examples in these instructions only illustrate how the CGDMTR should be completed and should not be relied on for technical guidance.

If these instructions do not fully cover your circumstances, you can contact:

the Pillar Two Project Team at pillar2project@ato.gov.au
a registered tax agent.

Using the CGDMTR instructions

Under the Minimum Tax law, the term 'group entity' has a particular meaning. In the general case, a group entity includes the UPE of an MNE group and an entity or arrangement that, through relationships of ownership or control have their assets, liabilities, income, expenses and cash flows included in the consolidated financial statements of the UPE.

For the purpose of these instructions, a reference to a 'group entity' means an entity that is part of your MNE group and includes:

the main entity of a GloBE permanent establishment
a GloBE joint venture, or
a GloBE joint venture subsidiary.

When we say 'you' in these instructions, we mean you as the lodging entity.

CGDMTR sections

The CGDMTR has 4 sections. You must complete all 4 sections. Following is a high-level description about the information required to complete each section.

Table: The CGDMTR sections
Section	Information required
Section 1: Client information	Section 1 requests your contact details. In the case of flow-through entities, we request additional details. In certain cases, the Minimum Tax law introduces obligations for entities not typically recognised in our tax administration system (e.g. certain joint operations). To help us recognise these entities in our system, we ask for additional details. If you are using a registered tax agent, their details must also be provided.
Section 2: Group entities and combined return	In Section 2, we ask you to provide 2 types of information about each group entity you are lodging on behalf of: 1. Identifying information for the group entity. 2. Any amounts payable, including registering a nil amount payable.
Section 3: Local and foreign lodgment notification	Section 3 asks: for details about your UPE if you have lodged a GloBE Information Return (GIR) in another jurisdiction. We ask you to provide details of the foreign currency used in the GIR to calculate Australian top-up taxes and translation to final liability amounts.
Section 4: Lodgment summary	Revise your responses and complete the Declaration to finalise the CGDMTR.

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:

Australian domestic top-up tax amount
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.

End of example

Record-keeping requirements

The Minimum Tax law introduces new record-keeping requirements in respect to the Australian global and domestic minimum tax.

Privacy

Our privacy policy contains important information about your privacy, including:

how you can access and seek correction of information we hold about you
how you may complain about a breach of the Australian Privacy Principles
how we will deal with any privacy complaint.

See further information at:

How to contact us

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using our online complaints form
phoning 1800 199 010
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