Section 2: Group entities and combined return

Before you start

Section 2 requires you to:

disclose details about each group entity (including the lodging entity), similar to the details requested in Section 1
indicate whether a foreign lodgment notification is or will be lodged for each group entity
show amounts payable including nil amount for each group entity.

Applicable group entity details

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, including your own details
will need to indicate which reporting obligations apply to each entity.

Depending on which obligations apply, you may need to report one or more of the following for each entity:

Foreign lodgment notification
IIR top-up tax amount, including a nil amount
UTPR top-up tax amount, including a nil amount (applies for fiscal years starting on or after 1 January 2025)
DMT top-up tax amount, including a nil amount.

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 include entities with a different fiscal year, such as where an entity has joined or left your MNE group during the fiscal year. The relevant entity will need to lodge separately.

Reminder: If you are lodging for more than 20 entities, seek alternative lodgment options; see Lodging, paying and other obligations for Pillar Two.

Table 2.1: Entity details
Item	Details
Client identifier	Provide at least one identifier for the lodging entity and one identifier for each group entity you are lodging on behalf of. Do not complete all 3 identifiers. The ARN should only be entered if the group entity does not have a TFN or ABN. A group entity that does not have its own identifier must obtain one before you can lodge the CGDMTR. For more information see: Apply for a TFN Applying for an ABN External Link Contact us at Pillar2Project@ato.gov.au Refer to Section 1: Lodging entity identifier for more information on client identifiers and how they are used in the CGDMTR. You don't need to quote your TFN. However, there may be delays in processing the CGDMTR if lodged without a TFN.
Name of the entity	Refer to Section 1: Name of lodging entity for information on how to report the name of the group entity.
Business address	Refer to Section 1: Address details for the lodging entity for information on how to report the business address of the group entity.
Entity type	Refer to Section 1: Lodging entity type for information about the different entity types.
Associate entity details	Refer to Section 1: Associate entity details for information about the associate entity’s details.

Combined lodgment information

Are you lodging a foreign lodgment notification for this entity?

Select Yes or No.
If you select No, you are confirming that the GIR will be lodged with the ATO.

Table 2.2: Summary of the foreign lodgment notification requirements
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 You must notify the ATO of 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 IIR/UTPR tax return and Australian DMT tax return for this entity?

Select Yes or No.

Not sure whether to select Yes or No?

Further information

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 LI 2025/28.

Reminder: Excluded entities don't have a lodgment obligation. You don't have to list details of excluded entities.

Select Yes if the entity is required to lodge both an AIUTR and a DMTR.
Select Yes if the entity is only required to lodge one of the AIUTR or DMTR, but not both
- this means the entity is exempt from lodging either the AIUTR or the DMTR, but not both of them
- selecting Yes will allow you to access the relevant fields.
Select No if the entity is exempt from lodging both the AIUTR and the DMTR.
Select No if the entity is only lodging the foreign lodgment notification. You can amend the CGDMTR later to lodge the AIUTR and DMTR.

For more information, see Global and domestic minimum tax.

Did you indicate you need to complete an AIUTR and/or DMTR for this entity?

Yes – Read on to Australian IIR/UTPR tax return and Australian DMT tax return.
No – Go to Section 3: Local and foreign lodgment notification.

Australian IIR/UTPR tax return and Australian DMT tax return

Is this entity required to report an Australian domestic top-up tax amount (including a nil amount)?

Select Yes 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, in the space provided. 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 if the entity is exempt from lodging a DMTR. For more information, see LI 2025/28.

Is this entity required to report an Australian IIR/UTPR top-up tax amount (including a nil amount)?

Select Yes 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/UTPR top-up tax amounts, including a nil amount, in the space provided. The sum of these amounts is an amount of Australian IIR tax, being tax payable under section 6 of the Minimum Tax Act.
Select the appropriate parent entity type from the list; see Appendix 1.
Select No if the entity is exempt from lodging an AIUTR. For more information about lodgment exemptions, see LI 2025/28.

Is this entity required to report an Australian UTPR top-up tax amount (including a nil amount)?

Select Yes 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 UTPR top-up tax amounts, including a nil amount, in the space provided. The sum of these amounts is an amount of Australian UTPR tax, being tax payable under section 10 of the Minimum Tax Act.
Select No if the entity is exempt from lodging an AIUTR. For more information about lodgment exemptions, see LI 2025/28.

Next steps

Return to Section 2: Group entities and combined return to add a new entity.
If you have added all relevant group entities, including your details, go to Section 3: Local and foreign lodgment notification.

More information

For more information and to go to other instruction sections, see: