House of Representatives
Taxation (Multinational - Global and Domestic Minimum Tax) Bill 2024
Taxation (Multinational - Global and Domestic Minimum Tax) Imposition Bill 2024
Treasury Laws Amendment (Multinational - Global and Domestic Minimum Tax) (Consequential) Bill 2024
Explanatory Memorandum
(Circulated by authority of the Assistant Minister for Competition, Charities and Treasury, the Hon Dr Andrew Leigh MP)Glossary
This Explanatory Memorandum uses the following abbreviations and acronyms.
| Abbreviation | Definition |
| AASB | Australian Accounting Standards Board |
| Activities Test | Activities Test as defined in the GloBE Rules |
| ADJR Act 1977 | Administrative Decisions (Judicial Review) Act 1977 |
| Acceptable FAS | Acceptable Financial Accounting Standard |
| Agreed Administrative Guidance | The following collection of documents:
|
| Assessment Bill | Taxation (Multinational—Global and Domestic Minimum Tax) Bill 2024 |
| ATO | Australian Taxation Office |
| Authorised FAS | Authorised Financial Accounting Standard |
| CFS | Consolidated Financial Statements |
| Commentary | Tax Challenges Arising from the Digitalisation of the Economy – Commentary to the Global Anti-Base Erosion Model Rules (Pillar Two) published by the OECD on 14 March 2022 and amended from time to time |
| Commissioner | Commissioner of Taxation |
| Consequential Bill | Treasury Laws Amendment (Multinational—Global and Domestic Minimum Tax) (Consequential) Bill 2024 |
| DMT | Domestic Minimum Tax |
| ETR | Effective Tax Rate |
| FANIL | Financial Accounting Net Income or Loss |
| FITO | Foreign Income Tax Offset |
| GloBE Rules | OECD GloBE Model Rules (as modified by the Commentary, Agreed Administrative Guidance and Safe Harbour Rules) |
| IIR | Income Inclusion Rule as defined in the GloBE Rules |
| Imposition Bill | Taxation (Multinational—Global and Domestic Minimum Tax) Imposition Bill 2024 |
| ITAA 1936 | Income Tax Assessment Act 1936 |
| ITAA 1997 | Income Tax Assessment Act 1997 |
| JV | Joint Venture |
| LTCE | Low-Taxed Constituent Entity |
| Minimum Tax law | Imposition Bill, Assessment Bill and Consequential Bill |
| MOCE | Minority-owned Constituent Entity |
| MNE | Multinational Enterprise |
| MNE Group | MNE Group as defined in the GloBE Rules |
| OECD | Organisation for Economic Cooperation and Development |
| OECD GloBE Model Rules | Tax Challenges Arising from the Digitalisation of the Economy – Global Anti-Base Erosion Model Rules (Pillar Two) published by the OECD on 20 December 2021 |
| OECD Model Tax Convention | OECD (2017), Model Tax Convention on Income and on Capital: Condensed Version 2017 |
| QIIR | Qualified Income Inclusion Rule |
| RBA | Reserve Bank of Australia |
| Rules | The Rules empowered to be made under the Assessment Bill or Consequential Bill. |
| Safe Harbour Rules | Safe Harbours and Penalty Relief: Global Anti-Base Erosion Rules (Pillar Two) published by the OECD on 20 December 2022 as well as Agreed Administrative Guidance published by the OECD on 17 July 2023 and 18 December 2023 |
| TAA | Taxation Administration Act 1953 |
| UPE | Ultimate Parent Entity as defined in the GloBE Rules |
| UTPR | Undertaxed Profits Rules as defined in the GloBE Rules |