House of Representatives

Taxation (Multinational - Global and Domestic Minimum Tax) Bill 2024

Taxation (Multinational - Global and Domestic Minimum Tax) Act 2024

Taxation (Multinational - Global and Domestic Minimum Tax) Imposition Bill 2024

Taxation (Multinational - Global and Domestic Minimum Tax) Imposition Act 2024

Treasury Laws Amendment (Multinational - Global and Domestic Minimum Tax) (Consequential) Bill 2024

Treasury Laws Amendment (Multinational - Global and Domestic Minimum Tax) (Consequential) Act 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:

•
Tax Challenges Arising from the Digitalisation of the Economy – Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two) published by the OECD on 2 February 2023;
•
Tax Challenges Arising from the Digitalisation of the Economy – Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two), July 2023 published by the OECD on 17 July 2023;
•
Tax Challenges Arising from the Digitalisation of the Economy – Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two), December 2023 published by the OECD on 18 December 2023.
•
Tax Challenges Arising from the Digitalisation of the Economy – Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two), June 2024 published by the OECD on 17 June 2024.
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

Copyright notice

© Australian Taxation Office for the Commonwealth of Australia

You are free to copy, adapt, modify, transmit and distribute material on this website as you wish (but not in any way that suggests the ATO or the Commonwealth endorses you or any of your services or products).