CGDMTR Appendix

Appendix 1: CGDMTR parent entity types

Table 1: Parent entity types

Parent entity type	Definition
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, permanent establishment, investment entity or insurance investment entity): that holds an ownership interest in another group entity of the MNE group, and in which ownership interest carrying rights to more than 20% of its profits are held by persons that are not group entities of the MNE group.
Ultimate parent entity (UPE)	An entity that holds a controlling interest in another entity and which does not have a controlling interest held by another entity, or a main entity that is not a group entity of another group and has one or more permanent establishments in another jurisdiction.

Appendix 2: CGDMTR glossary of acronyms

Table 2: Acronyms used in this publication without accompanying explanations

Acronym	Spelled out
AIUTR	Australian IIR/UTPR Tax Return
ABN	Australian business number
ARN	ATO reference number
CGDMTR	Combined global and domestic minimum tax return
DFE	designated filing entity
DLE	designated local entity
DMTR	Domestic Minimum Tax Return
GIR	GloBE Information Return
GloBE rules	OECD Global Anti-Base Erosion Model rules
IIR	Income Inclusion Rule
MNE group	multinational enterprise group
PRN	payment reference number
TIN	tax identification number
UTPR	Undertaxed Profits Rule

 

Appendix 3: GloBE joint ventures

There may be specific CGDMTR lodgment considerations to be aware of in respect of GloBE JVs and GloBE JV subsidiaries due to their distinct classification and the special deeming rules that apply to them (see When and how the Pillar Two rules apply).

These lodgment considerations reflect how GloBE JVs and GloBE JV subsidiaries compute top-up tax on a standalone basis and may have DMTR lodgment and payment obligations separate from the broader MNE group. In certain circumstances, the fiscal years used for computation, payment and lodgment may not align with the fiscal year of the broader MNE group (which is generally the accounting period of the UPE).

We acknowledge the complexities in these situations. We have provided the following instructions on how to fill out the CGDMTR. If you believe these can't accommodate the required compliance outcome in your circumstance, don't assume the obligation no longer applies. Instead, contact us, retain evidence of the issue and any attempted lodgment or payment, and consider whether a deferral or penalty-remission position is required.

Deemed JV group

When calculating top-up tax, GloBE JVs and GloBE JV subsidiaries are treated as constituent entities of a separate MNE group (deemed MNE group or JV group), separate from the MNE group or groups that hold the ownership interests (the broader MNE group). The GloBE JV is treated as the UPE of the deemed MNE group, and the GloBE JV subsidiaries as constituent entities of the group. Refer to section 6-75 of the Australian Minimum Tax Rules.

GloBE JV and GloBE JV subsidiaries may themselves be allocated Australian domestic top-up tax under section 2-25. This differs from IIR and UTPR top-up tax which (although still computed separately) is allocated to the entities in the broader MNE group.

As a result, GloBE JVs and GloBE JV subsidiaries may be required to lodge a DMTR under section 127-55 of Schedule 1 to the TAA, but are not required to lodge the GIR or the AIUTR. Any IIR or UTPR outcomes relating to a GloBE JV or GloBE JV subsidiary are the responsibility of the relevant parent entity or entities in the broader MNE group, rather than the JV itself.

JV DMTR lodgment

Despite the possibility of being a GloBE JV of 2 applicable MNE groups, a GloBE JV and its GloBE JV subsidiaries have one single DMTR obligation each for a fiscal year.

GloBE JVs and GloBE JV subsidiaries can meet their DMTR obligations when their relevant DMTR information is included in a lodged CGDMTR. To facilitate ease of lodgment the ATO has provided 2 options:

1. Separate JV lodgment: The GloBE JV lodges a standalone CGDMTR for the deemed JV group (the GloBE JV and its GloBE JV subsidiaries).
   • The ATO will allow GloBE JV subsidiaries to appoint the GloBE JV as the DLE albeit them not being considered a group entity of an applicable MNE group.
   • Alternatively, the GloBE JV and GloBE JV subsidiaries can each lodge separately. These instructions however focus on when a GloBE JV lodges on behalf of the JV group.
2. Combined lodgment: The GloBE JV and GloBE JV subsidiaries can nominate a DLE of the broader MNE group which lodges the CGDMTR on their behalf and includes the outcomes for the GloBE JVs and GloBE JV subsidiaries in one combined lodgement.

If nominating a DLE of the broader MNE group to lodge a combined CGDMTR, select a DLE in the broader MNE group with a fiscal year end that aligns with the GloBE JV's fiscal year. Otherwise, you are required to lodge on a standalone CGDMTR.

Generally, the due date for lodgment during the transition year is 18 months after the end of the first fiscal year. In subsequent years, the due date for lodgment is 15 months after the end of the fiscal year. Where lodgments are due before 30 June 2026, transitional provisions under section 69 of the Treasury Laws Amendment (Multinational—Global and Domestic Minimum Tax) (Consequential) Act 2024 applies to deem the first lodgment date to be 30 June 2026.

 

CGDMTR JV specific instructions

GloBE JV and GloBE JV subsidiaries can lodge on a standalone or combined (with the broader MNE group) basis. This will impact how you complete the CGDMTR. Following are some specific label completion notes.

Section 1: Client information

Refer to this when filling out Section 1: Client information.

Reporting Fiscal Year – standard 12 month 

Separate JV lodgment: GloBE JV's fiscal year.

• The reporting fiscal year if lodging on a standalone basis is the GloBE JV's accounting period. The fiscal year of the GloBE JV and GloBE JV subsidiaries is that of the GloBE JV, which is the accounting period for which the GloBE JV prepares its financial statements. The fiscal year of the GloBE JV is the relevant fiscal year for the purpose of determining lodgment deadlines for the DMTR. Where a GloBE JV or GloBE JV subsidiary's fiscal year is not aligned with that of the broader MNE group, the relevant fiscal year for the GloBE JVs and GloBE JV subsidiaries will be the GloBE JV's fiscal year that ends during the broader MNE groups fiscal period.

Combined lodgment: UPE's fiscal year.

• The reporting fiscal year of the broader MNE group (whether lodging combined with the GloBE JV and its GloBE JV subsidiaries, or separately and exclusive of the JV group) is generally the UPEs accounting period. For more information, refer to Misaligned fiscal years.

Lodging entity information  

Separate JV lodgment: Lodge as a standalone group entity.

• The ATO will allow JVs to lodge in the capacity of a group entity of the MNE group. A group entity in this case can mean the GloBE JV or the JV group (the GloBE JV and its GloBE JV subsidiaries).

Combined lodgment: Lodge as a DLE and complete the details for the GloBE JV in addition to the other group entities you are lodging on behalf of.

Associate entity details

If the GloBE JV is incorporated (a company), don't complete this section.

If the GloBE JV is not a separate legal person, include details of one associate entity. If the GloBE JV has more than one associate entity, include the associate entity that is most readily contactable.

Section 2: Group entities and combined return

Refer to this when filling out Section 2: Group entities and combined return.

Separate JV lodgment: If the JV group is lodging on a standalone basis, provide the details of the GloBE JV.

Are you lodging a foreign lodgment notification for this entity?

Treat this question as 'Does a GIR of the broader MNE group lodged overseas include the relevant GloBE JV information?' Select Yes to declare that the applicable MNE group's GIR has been lodged overseas. Select No to declare that the applicable MNE group's GIR has been lodged in Australia. The response is to facilitate completion of the Section 3: GIR lodgment details.

Are you lodging an Australian IIR/UTPR tax return and Australian DMT tax return for this entity?

Select Yes if the GloBE JV is required to lodge a DMTR. Enter the amounts, including a nil amount, in the space provided. Select no if the GloBE JV is exempt from lodging a DMTR. For more information, see LI 2025/28.

Is the entity required to report an Australian IIR Top-up Tax amount (including a nil amount)?

Select No.

Combined lodgment: Lodge as the DLE of the MNE group as normal.

Section 3: Local and foreign lodgment notification

Refer to this when filling out Section 3: Local and foreign lodgment notification.

UPE details

Separate JV lodgment: Provide the details of the UPE of the broader MNE group. If you are part of two MNE groups, provide the details of the UPE of either.

Is the Designated Local Entity or the Group Entity who is lodging this return the same as the UPE?

Select No.

GIR lodgment details and foreign lodgment notification

Complete this section as if it were being completed by the UPE of the applicable MNE group.

CGDMTR instructions index

• CGDMTR general information
  • About the CGDMTR
  • Lodgment assessment and payment
• CGDMTR instructions
  • Section 1: Client information
  • Section 2: Group entities and combined return
  • Section 3: Local and foreign lodgment notification
  • Section 4: Lodgment summary
  • CGDMTR Appendix