Lodgment
The Minimum Tax law introduces new lodgment obligations for members of an in-scope multinational enterprise group (MNE group). However, you may not need to lodge if you are either an excluded entity or are exempted from lodging.
Lodging electronically
The Combined global and domestic minimum tax return (CGDMTR) must be lodged electronically. You can lodge the CGDMTR via Online services for business, or your tax agent can lodge the CGDMTR via Online services for agents.
You may also lodge using a third-party software package that supports electronic lodgment.
For a designated local entity (DLE) lodging the form on behalf of group entities, the ATO online services platform has a limitation of 20 entities, which includes the DLE. If a DLE needs to lodge for more than 20 group entities, the CGDMTR will need to be lodged through an API solution, which will support CGDMTR lodgments for up to 300 entities.
See further details lodging, paying and other obligations for Pillar Two.If there are any issues lodging electronically, contact us at Pillar2Project@ato.gov.au.
Tax agent requirements to lodge
A tax agent has to be nominated at the income tax level or at the global and domestic minimum tax (GDMT) account level in order to lodge the CGDMTR.
To nominate a specific agent at the GDMT account level, refer to How to nominate your registered agent.
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 it 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, and
- expectations in respect of lodgment obligations for the global and domestic minimum tax.
See further details about penalties.