Lodging, paying and other obligations for Pillar Two

Four new lodgment requirements are introduced as part of the Australian global and domestic minimum tax, consistent with the Global Anti-Base Erosion Model RulesExternal Link (GloBE Rules). These are:

• GloBE Information Return (GIR)
• Foreign lodgment notification
• Australian IIR/UTPR Tax Return (AIUTR)
• Australian DMT Tax Return (DMTR).

The combined global and domestic minimum tax return

The foreign lodgment notification, AIUTR and DMTR will be combined in one form, the Combined global and domestic minimum tax return (CGDMTR).

The separate lodgment requirements are met when the relevant section of the CGDMTR is completed and the CGDMTR is lodged.

The online form for the CGDMTR will be accessible in ATO online services via:

• Online services for agents
• Online services for business

Only persons with strong identity strength in myID and that use myID to log in, can access and lodge the CGDMTR via Online services for business and Online services for agents. For more details, refer to Increase your online security with myID.

Access Manager permissions must be provided to enable access to the form in ATO online services.

A taxpayer with a valid Australian business number (ABN), if not already registered, may register for access to Online services for business.

All registered tax agents may register to use Online services for agents.

You may also lodge through application programming interface (API)-enabled software. Software developers can obtain the necessary API specifications and guidance:

• from the ATO API PortalExternal Link, or
• by contacting DPO@ato.gov.au.

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.

A group entity that does not have a lodgment obligation is not counted towards the abovementioned 20 and 300 entity limits. For instance, in most cases subsidiary members of tax consolidated groups do not need to be listed in the CGDMTR if they:

• are exempt from lodging both the AIUTR and DMTR, and
• have appointed a DLE to lodge their foreign lodgment notification.

These subsidiary members consequently would not be counted in the 20 or 300 entity limit.

The API channel and Online services for business require the DLE to have an ABN to lodge the CGDMTR. The form can still be lodged and processed where the group entities listed in the CGDMTR do not have an ABN.

The GIR and the CGDMTR are separate returns and are lodged separately. The GIR is a global return, while the CGDMTR is an Australia-specific domestic return. The CGDMTR does not contain computational information but enables the triggering of Australia's domestic assessment and payment provisions.

You can:

• view the CGDMTR online instructions
• view sample PDFs of the CGDMTR
• contact us at Pillar2Project@ato.gov.au if you are
  • a taxpayer unable to lodge through ATO online services or an API solution, or
  • a DLE lodging on behalf of more than 300 entities.

GIR and foreign lodgment notification

The GIR is an information return:

• developed by the Organisation for Economic Co-operation and Development (OECD) Inclusive Framework
• containing data to enable tax administrators to perform risk assessment and assess the correctness of an entity's top-up tax liability.

The GIR is a single information return for the multinational enterprise group (MNE group), consisting of:

• a general section
• various jurisdictional sections.

Under the general section, an MNE group:

• provides information about the MNE group as a whole
• identifies the filing constituent entity and provides its corporate structure.

The jurisdictional sections provide information about:

• each jurisdiction where the MNE group is operating
• jurisdictions where relevant safe harbours and exclusions apply.

For jurisdictions where safe harbours and exclusions do not apply, the MNE group would report its detailed effective tax rate (ETR) computations, followed by top-up tax computations and the allocation of top-up tax, if necessary.

The sections that need to be provided in the GIR depend on the dissemination approach, as agreed upon by the OECD Inclusive Framework. Refer to Australian record keeping requirements for the GIR to see what the ATO requires under the dissemination approach.

Under Subdivision 127-A in Schedule 1 to the Taxation Administration Act 1953 (TAA), the default requirement is for each group entity of an MNE group that is GloBE located in Australia to lodge a GIR. In the usual case, a group entity is an entity that, through relationships of ownership or control, have their assets, liabilities, income, expenses and cash flows included in the consolidated financial statements of the ultimate parent entity (UPE).

Consistent with the GloBE Rules, Subdivision 127-A in Schedule 1 provides the ability for group entities to nominate another entity in the MNE group to lodge one single GIR on their behalf. This can comprise of:

• a designated local entity (DLE) lodging with the ATO
• a foreign UPE or a designated filing entity (DFE) lodging with a foreign government agency
  • in this case, each Australian group entity must either lodge its own foreign lodgment notification, or the nominated DLE can lodge a single foreign lodgment notification on behalf of each group entity.

An Australian group entity has a GIR lodgment obligation even if the Australian IIR/UTPR tax or Australian DMT tax amount is nil.

Lodging the GIR in Australia

The GIR XML file can be lodged with the ATO using the Online services for agents or Online services for business file transfer facility. Taxpayers with a tax file number (TFN) may nominate a tax agent to lodge the GIR on their behalf.

You may need to contact your digital service provider to check whether they support GIR XML file generation. Digital service providers can access GIR XML file specifications required to lodge with the ATO, see GloBE Information Returns (GIR) OECD 2026 specification v1.0 | ATO Software DevelopersExternal Link.

Similar to the lodgment of country-by-country reports, the channel will indicate if lodgment has been successful. The lodgment will then go through a validation process and if the relevant option is selected, an email advising the outcome will be sent to the contact email address provided in the file transfer facility.

When lodging the GIR locally with the ATO, either each Australian group entity or a DLE of an MNE group can lodge. There is no need to lodge a foreign lodgment notification with the ATO.

The GIR will be lodged separately from the CGDMTR. The AIUTR and DMTR are contained in the CGDMTR, but it does not contain the GIR.

DFE or UPE lodging the GIR overseas

When lodging the GIR with a foreign government agency and not locally with the ATO, to effectively fulfil each Australian group entity's GIR lodgment obligation:

• The GIR must be lodged on time in the foreign jurisdiction (if not met, the group will still have Australian filing obligations).
• Notification must be given to the Commissioner of Taxation by either each Australian group entity itself or the nominated DLE by lodging a foreign lodgment notification form. The foreign lodgment notification is included in the CGDMTR.
  • Where a DLE has been nominated to lodge the foreign lodgment notification, the details of each subsidiary member of a consolidated group (TCG) or multiple entry consolidated (MEC) group are not required to be listed in the foreign lodgment notification section of the CGDMTR where those subsidiary members are exempt from lodgment of both the AIUTR and DMTR under LI 2025/28.The head company of the TCG or head companies and any eligible tier 1 companies of an MEC group must be listed in this section.

For further information, refer to Tax consolidated group lodgments for Pillar Two.

• The foreign government agency that the GIR is lodged with must have a Qualifying Competent Authority Agreement (QCAA) that is in effect with Australia. The GIR will then be exchanged with the ATO as per the QCAA and in line with the dissemination approach agreed by the OECD Inclusive Framework.
  • If the GIR is lodged with a foreign government agency but it is not exchanged with the ATO within the time period specified in the QCAA, the ATO may by written notice require that the GIR be locally lodged with the ATO.
  • On 28 January 2026, Australia became a signatory of the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA), which is a QCAA for the purposes of lodgment. Australia is now included on the list of GIR MCAA signatories (PDF, 108 KB)External Link.
  • The list of activated bilateral exchange relationships under the GIR MCAA for the automatic exchange of GloBE information can be found under OECD Exchange relationshipsExternal Link. The list shows the jurisdictions with which Australia has a QCAA that is in effect. The OECD will update this list as new bilateral exchange relationships are activated.

Entities will still have obligations to lodge the AIUTR and DMTR with the ATO even if the GIR is lodged overseas.

AIUTR and DMTR

The AIUTR and DMTR are Australian domestic tax returns, included in the CGDMTR. They enable the triggering of Australia's domestic assessment and pay provisions. The GIR is an information only return and does not result in a top-up tax assessment.

The AIUTR is for the global minimum tax, while the DMTR is for the domestic minimum tax.

Under Subdivision 127-A in Schedule 1 to the TAA, each group entity:

• is required to lodge an AIUTR where they have an Australian IIR/UTPR tax amount (including a nil amount), unless a lodgment exemption applies
• is required to lodge a DMTR where they have an Australian DMT tax amount (including a nil amount), unless a lodgment exemption applies.

Group entities can appoint a DLE to lodge their AIUTR and DMTR on their behalf.

Note: Excluded entities don't have an obligation to lodge the AIUTR or DMTR, nor do they have an obligation to lodge the GIR and foreign lodgment notification form.

 

 

Nomination of a DLE

An MNE group can nominate a DLE to lodge a GIR or foreign lodgment notification on behalf of Australian group entities. If they do so, they can also choose to nominate that same DLE to lodge AIUTRs and DMTRs on behalf of Australian group entities.

A DLE must:

• be a group entity that is GloBE located in Australia for the fiscal year
• be nominated by every other group entity that is GloBE located in Australia for the fiscal year to lodge the GIR or foreign lodgment notification
• be nominated by every group entity with an AIUTR and DMTR lodgment obligation to lodge those returns, if the MNE group also wishes to nominate the DLE to lodge the AIUTR and DMTR
• not be an excluded entity or a permanent establishment.

How to nominate a DLE

There is no specific form that an MNE group must lodge or use to nominate a group entity as a designated local entity (DLE). MNE groups must identify the DLE in the relevant section of the GIR and the CGDMTR for the fiscal year. The DLE must complete relevant declarations in those returns as the filing entity.

An MNE group must keep appropriate internal written records of each group entity nominating the DLE. We may request a copy of the nomination records for compliance and engagement purposes.

Failure to nominate a DLE

If an MNE group does not nominate a DLE or only nominates one for the GIR and not the CGDMTR (which includes the AIUTR and DMTR), each individual entity with those lodgment obligations must lodge its own return or notice.

 

Lodgment for entities leaving and joining applicable MNE groups

If an entity leaves an applicable MNE group and joins another applicable MNE group part way through the fiscal year, the transitioning entity can have separate Australian lodgment obligations in respect of each group for the fiscal year in which the transfer occurs.

It is important that you contact us at Pillar2Project@ato.gov.au before lodgment if you have a transitioning entity that has separate DMTR or AIUTR lodgment obligations for each group in this scenario. We will need to tell you how to lodge for that entity to ensure its lodgments can be accepted by our systems.

You do not need to contact us if the entity does not have separate DMTR or AIUTR lodgment obligations for each group. For example, you do not need to contact us if the entity only has DMTR and AIUTR obligations in respect of one of those groups but not in respect of the other because:

• the other group is not in scope of Australia's Minimum Tax law for the fiscal year
• the entity benefits from DMTR and AIUTR lodgment exemptions for the other group for the fiscal year, such as those that may apply to subsidiary members of tax consolidated groups; for example, where a standalone entity leaves an applicable MNE group and joins another applicable MNE group as a subsidiary of a TCG (and it is exempt from lodging a DMTR and AIUTR for that MNE group), you do not need to contact us before lodging the returns for the first MNE group.

Similarly, you do not need to contact us if the entity does not have DMTR or AIUTR lodgment obligations for any group for the fiscal year due to applicable lodgment exemptions. For example, you do not need to contact us before lodgment where a subsidiary member of a TCG transitions to another TCG as a subsidiary member in another applicable MNE group, provided that DMTR and AIUTR lodgment exemptions apply to the entity in respect of both groups.

Lodgment due dates

The GIR, foreign lodgment notification, AIUTR and DMTR are required to be lodged:

• 18 months after the end of the first fiscal year
  • the extended lodgment period applies only to MNE groups in scope from the first applicable fiscal year and does not apply to MNE groups that become in scope in a later fiscal year, and
• 15 months after the end of the subsequent fiscal years.

The Commissioner has the ability to extend the lodgment deadline for the AIUTR and DMTR, but not the GIR or the foreign lodgment notification.

Lodgment due dates for the first fiscal year

Year-end date	Lodgment due date
Fiscal years ending before 31 December 2024 (fiscal years less than 12 months)	30 June 2026
31 December 2024	30 June 2026
31 January 2025	31 July 2026
28 February 2025	31 August 2026
31 March 2025	30 September 2026
30 April 2025	31 October 2026
31 May 2025	30 November 2026
30 June 2025	31 December 2026
31 July 2025	31 January 2027
31 August 2025	28 February 2027
30 September 2025	31 March 2027
31 October 2025	30 April 2027
30 November 2025	31 May 2027

See additional information for misaligned fiscal years on the Specific issues for Pillar Two page.

Registration

We do not require MNE groups to register for Pillar Two prior to their first lodgment of a GIR and CGDMTR. However, entities may require the GDMT account and role to be created prior to lodgment, in order to nominate a tax agent for Pillar Two purposes.

To lodge a GIR and CGDMTR online, a DLE or group entity needs to log in to ATO online services for business or their agent can lodge on their behalf via ATO online services for agents. For more information on how to access these services, refer to the:

• Online services for agents user guide
• Online services for business user guide

When the first lodgment of CGDMTR is received, a Global and Domestic Minimum Tax (GDMT) account and relevant role will be automatically created in our system.

However, entities may require the GDMT account and role to be created prior to lodgment, in order to nominate a tax agent for Pillar Two purposes. This can be completed by lodging a request to create a GDMT account through either:

• Online services for business using secure mail
  • open a New message
  • select the Topic: Global and domestic minimum tax
  • select the Subject: Request for account and role
  • provide full entity details and the fiscal year end date and start date for the lodgment in your request
• Online services for agents using practice mail (only agents already linked at client level can make this request)
  • open a New message
  • select the Topic: Global and domestic minimum tax
  • select the Subject: Request for account and role
  • provide full entity details and the fiscal year end date and start date for the lodgment in your request
• entities that cannot access online services and do not have a current client level agent must contact us (as follows). Overseas taxpayers or agents cannot lodge unless they are already in our systems and linked at client level to a GDMT account. The entity itself will need to request this, as the agent proposed to be nominated for Pillar Two is not yet linked to the account
  • email the Pillar2Project@ato.gov.au
  • phone 13 28 66 (businesses)
  • provide full entity details and the fiscal year end date and start date for the lodgment in your request.

Note that the GDMT account and role creation request will not be able to be completed without full entity details and fiscal year of the lodgment.

After the GDMT account and role is created, Agent nomination can be completed.

Agents already linked at the client level will be able to lodge your CGDMTR.

Tax agents may remove client to agent linking by following Remove client in the Online services for agents user guide.

Legislative instrument

Entities may be exempt from certain lodgment aspects of the Australian global and domestic minimum tax in certain circumstances.

Specifically, subsections 127-35(5) and 127-45(5) in Schedule 1 to the TAA allow the Commissioner to, by way of a legislative instrument, make a determination specifying circumstances in which a group entity need not lodge an AIUTR and DMTR for a fiscal year, respectively.

The Commissioner cannot exempt entities from lodging the GIR or foreign lodgment notification.

LI 2025/28

The Legislative lnstrument LI 2025/28 Taxation Administration (Exemptions from Requirement to Lodge Australian IIR/UTPR tax return and Australian DMT tax return) Determination 2025 together with its explanatory statement has been registered and published on the Federal Register of Legislation on 22 December 2025.

It is aimed at exempting an entity from lodgment when its top-up tax liability will always be nil.

Under the legislative instrument, entities that may be exempt from lodging a DMTR for a fiscal year include:

• certain subsidiary members of tax consolidated groups or multiple entry consolidated (MEC) groups
• entities that are not GloBE located in Australia, other than a stateless constituent entity created in Australia or a main entity of an Australian GloBE permanent establishment
• certain GloBE securitisation entities
• certain flow-through entities that cannot have an Australian DMT tax liability.

Given the AIUTR covers both Australian IIR tax and Australian UTPR tax liabilities, entities will only be exempt from lodging an AIUTR for a fiscal year under specific circumstances in which these liabilities will always be nil.

The legislative instrument sets out 2 circumstances that must both be met for a fiscal year before the exemption will apply:

1. Entities that may fall within the first circumstance relating to the IIR include
   • entities that are not parent entities, or which are parent entities but which are not GloBE located in Australia
   • parent entities that are GloBE located in Australia, but which only hold direct and indirect ownership interests in other group entities or GloBE joint ventures that are themselves GloBE located in Australia
   • parent entities that are GloBE located in Australia, but which cannot have an Australian IIR tax liability greater than zero because a higher-tier parent entity is required to apply a qualified income inclusion rule.
2. These entities must also be covered by the second circumstance relating to the UTPR in order to benefit from the exemption. Entities that may do so include
   • certain subsidiary members of consolidated groups and MEC groups
   • entities that are not GloBE located in Australia, other than a main entity of an Australian permanent establishment
   • entities that would have an Australian UTPR tax liability of nil due to the application of one or more qualified income inclusion rules or in combination with the group's eligibility for the transitional UTPR safe harbour
   • the fiscal year starts on or before 31 December 2024
   • certain GloBE investment entities, insurance investment entities and GloBE securitisation entities.

Entities may be exempt from the requirement to lodge one or both of AIUTR and DMTR for a fiscal year depending on their circumstances.

 

 

 

Obligations and liabilities for specific entity types

GloBE permanent establishments

For GloBE permanent establishments located in Australia, all lodgment and payment obligations are placed on its main entity. The main entity is required to give the Commissioner a GIR, AIUTR, and DMTR in respect of the GloBE permanent establishment. The GIR and foreign lodgment notification requirements apply to the main entity as if it were located in Australia.

GloBE joint ventures

GloBE JVs and GloBE JV subsidiaries are not required to separately lodge the GIR or the AIUTR. However, disclosure requirements regarding GloBE JVs and GloBE JV subsidiaries are required in the GIR for applicable MNE groups that hold ownership in GloBE JVs.

GloBE JVs and GloBE JV subsidiaries are required to lodge a DMTR under section 127-55 of the TAA and may be liable to pay domestic minimum tax. The Commissioner's legislative instrument outlines circumstances in which a GloBE JV or GloBE JV subsidiary need not lodge a DMTR.

A GloBE JV of an applicable MNE group and its GloBE JV subsidiaries may appoint a DLE of that applicable MNE group to lodge their DMTRs on their behalf. If an entity is a GloBE JV of 2 applicable MNE groups for a fiscal year, the GloBE JV and its GloBE JV subsidiaries may only appoint a DLE of one of those groups to lodge their DMTRs.

Accounting joint operations

Stakeholders have specifically asked us what the lodgment obligations are for arrangements that are treated as joint operations for accounting purposes. There is no concept of a joint operation for accounting purposes under the global and domestic minimum tax. Whether such an arrangement has lodgment obligations depends on whether it is classified as a constituent entity. If it is, the standard lodgment obligations applicable to group entities can apply, which includes lodgment of the GIR, AIUTR and DMTR. For more information on the classification of joint operations, see When and how the Pillar Two rules apply.

The legislative instrument includes exemptions that may apply to certain joint operations classified as constituent entities. These include the following:

• About the AIUTR
  • A group entity that is not GloBE located in Australia will not be required to lodge an AIUTR, unless it is a main entity of an Australian permanent establishment (refer to section 11 of the instrument). Also, this exemption covers a joint operation created in Australia that is classified as a flow-through entity, except where it is a parent entity that must apply Australia's IIR.
• About the DMTR
  • A joint operation that is not GloBE located in Australia will not be required to lodge a DMTR (refer to section 8 of the instrument). However, this particular exemption does not apply to a joint operation created in Australia that is classified as a flow-through entity. Neither does it apply to an entity that is a main entity of an Australian permanent establishment.
  • Where the joint operation is a flow-through entity created in Australia, lodgment will not be required where the Australian domestic top-up tax amount cannot be greater than zero provided certain circumstances are met (refer to section 10 of the instrument). These circumstances include that the joint operation is neither a reverse hybrid entity, a main entity of an Australian permanent establishment, or a UPE that is GloBE located in Australia. In addition, for the exemption to apply, the joint operation must have all its Financial Accounting Net Income or Loss reduced to zero under the Australian Minimum Tax Rules and must not have a domestic top-up tax amount greater than zero.

We anticipate that a number of joint operations that are flow-through entities may not have an obligation to lodge an AIUTR and DMTR based on the exemptions above. Taxpayers should consider the legislative instrument carefully regarding whether they meet the conditions for the relevant exemption.

About the GIR, joint operations classified as constituent entities are not required to lodge a GIR if they are not GloBE located in Australia. This includes flow-through entities created in Australia that are treated as stateless constituent entities.

However, MNE groups must still report information about each constituent entity in the GIR. We will apply an administrative approach and accept GIRs that do not list joint operations as separate constituent entities, provided the following specific circumstances are met:

• The joint operation is a flow-through entity created in Australia and is not a trust, GloBE partnership, reverse hybrid entity or main entity of an Australian permanent establishment.
• The joint operation could not have an Australian domestic top-up tax amount greater than zero.
• The financial records available for the joint operation do not enable separate reporting as a constituent entity in the GIR for the detailed disclosure requirements.
• The participants in the joint operation that are group entities are constituent entities and report their proportionate share of the joint operation’s income, covered taxes, and other relevant information as part of their disclosures in the GIR.

GloBE partnerships

'GloBE partnership' is defined under subsection 128-20(6) of the Taxation Administration Act 1953 (TAA) and takes its meaning from the ordinary concept of partnership. It is distinct from the definition of partnership in subsection 995‑1(1) of the ITAA 1997 and specifically includes corporate limited partnerships.

Extended application to unincorporated entity types

Targeted rules accommodate different entity types to ensure obligations and liabilities imposed can be administered effectively.

For trusts, partnerships and other unincorporated entities, Subdivision 128-B in Schedule 1 to the TAA extends the entities to which obligations and liabilities in respect of the Australian global and domestic minimum tax apply.

Extended application under the TAA

Entity type	Entity subtype	Entity that obligation, offences and joint and several liability is applied to	Provision
Trusts	n/a	The trustees, regardless of whether the trustee is a member of the applicable MNE group	128-15
GloBE partnerships	Not a GloBE JV or GloBE JV subsidiary	The partners, regardless of whether the partner is a member of the applicable MNE group.	128-20
GloBE partnership	Unincorporated GloBE JV	Each partner of the unincorporated JV that is a group entity of the applicable MNE group.	128-25
GloBE partnership	Unincorporated GloBE JV subsidiary	Each partner that is the GloBE JV, or another GloBE JV subsidiary, or a group entity of the applicable MNE group.	128-25
Not trust or GloBE partnership	Unincorporated GloBE JV	Each group entity of the applicable MNE group that holds a direct ownership interest in the GloBE JV.	128-25
Not trust or GloBE partnership	Unincorporated GloBE JV subsidiary	The GloBE JV and each group entity of the applicable MNE group that holds a direct ownership interest in the GloBE JV.	128-25
Not trust or GloBE partnership	Unincorporated group entities	Each group entity of the applicable MNE group to which a portion of the unincorporated group entity’s assets, income, expenses, cashflows and liabilities belong, or that is a member of the management committee of the unincorporated group entity.	128-25

Note: Both columns under entity type (entity type and entity subtype) must be met for the relevant provision to apply.

Generally, any entity listed above that the extended application applies to can discharge the obligation or liability.

Liability

Top-up tax liabilities

Global and domestic minimum tax is payable by entities that have a top-up tax amount for the fiscal year.

The global minimum tax brings the total effective tax in another jurisdiction up to 15% by charging:

• Australian IIR tax equal to the sum of its IIR top-up tax amounts
• Australian UTPR tax equal to the sum of its UTPR top-up tax amounts.

The domestic minimum tax brings the total effective tax in Australia up to 15% by charging Australian DMT tax equal to the sum of its domestic top-up tax amounts.

An entity becomes liable for top-up tax on the same day the return that gives rise to the assessment is due, generally 15 months after fiscal year end and 18 months after the first fiscal year end. Shortfall interest charge, general interest charge and penalties can also apply. Where an Australian group entity is a member of a tax consolidated group, the head entity is allocated the top-up tax amounts for the purposes of liabilities for DMT and UTPR tax. For more information on top-up tax allocations, see Top-up tax for tax consolidated groups.

The Taxation (Multinational – Global and Domestic Minimum Tax) Rules 2024External Link and associated Explanatory Statement (PDF, 1.55MB)External Link detail the mechanisms for allocating and computing top-up tax amounts.

Joint and several liability

All group entities of the MNE group become jointly and severally liable to pay top-up tax, meaning the ATO can collect global or domestic minimum tax amounts or related charges from any group entity in the MNE group. Generally, any group entity can discharge the liability on behalf of all group entities in the group.

Specifically, section 128-5 in Schedule 1 to the TAA provides that if an amount is payable by a group entity of an applicable MNE group, that group entity and each other group entity of that group is jointly and severally liable to pay that amount. An amount includes top-up tax, general interest charge, shortfall interest charge, and penalties.

Additional joint and several liability rules apply to GloBE JVs of an applicable MNE group. Where GloBE JVs and GloBE JV subsidiaries are liable to pay top-up tax, each of these entities and the group entities of the MNE group that have direct ownership interest in the JV are jointly and severally liable to pay the amount.

There are exceptions to this. Joint and several liability does not apply:

• to entities that meet the conditions in subsection 820-39(3) of the Income Tax Assessment Act 1997, or
• where Australian law prohibits the entity from entering into an arrangement under which it becomes subject to such a liability.

Payments

Payment reference number

A payment reference number (PRN) is issued for each group entity when any of its top-up tax liabilities is greater than zero. The same PRN applies to all 3 top-up tax liabilities. The PRN will be provided to the lodging entity as part of the lodgment success message via Online services for business, Online services for agents or an API solution.

The PRN provided on the lodgment confirmation page may be different to the one on the notices and account summary screen. Either of them can be used to make payment to the Global and Domestic Minimum Tax (GDMT) account.

The group entity, DLE and tax agent can view a PRN through Online services for business, Online services for agents or by phoning the ATO.

How to pay

Top-up tax liabilities should be paid individually by each group entity of an MNE group.

The DLE can make a payment for itself and for the group entities it is lodging for. However, the correct PRN for each corresponding group entity must be used. Failure to do so may lead to delays in payment processing. For example, the DLE should not make a payment for another group entity using the DLE's PRN.

For details on how to pay, refer to 'Payment' in the Pillar Two CGDMTR online form instructions 2024.

To minimise delays in processing times and in case there is an available refund, ensure the financial institution details for your GDMT account are up to date.

Deferrals

Lodgment deferral

Every in-scope taxpayer will be granted automatic 30-day deferral for their AIUTR and DMTR lodgments for fiscal years commencing in 2024; to allow taxpayers and their advisers extra time to ensure they are ready to lodge on time. You do not need to do anything; the lodgment deferral will appear automatically on the taxpayer account. This automatic deferral doesn't apply to later fiscal years commencing after 2024.

However, an automatic payment deferral will not be granted for any IIR, UTPR or DMT top-up tax liability in the first year. If you have top-up tax payable for the first year, you will still need to pay on or before the original due date despite lodgments being automatically deferred for 30 days for the first year. You can, however, apply for a payment deferral as outlined below, which will be considered in line with existing guidance.

Any further period of lodgment deferral for the first year, beyond the automatic deferral of 30 days, or for subsequent years, can be requested via practice mail or secure mail on the ATO online channels using the Combined global and domestic minimum tax lodgment deferral request form (NAT 75810) below.

Combined Global and domestic minimum tax return lodgment deferral request form

Download the Combined Global and domestic minimum tax return lodgment deferral request form (NAT 75810) (XLSX, 110KB)This link will download a file.

If you do not have access to ATO online channels, contact the Pillar Two mailbox at Pillar2Project@ato.gov.au, and an ATO secured transfer facility (Kiteworks) will need to be used to submit the form.

Each form can only contain a lodgment deferral request for one in-scope MNE group. For example, a form can contain requests for one DLE and all the MNE group's group entities with Australian AIUTR and DMTR lodgment obligations.

There is no limit to the number of group entities that can be listed in the form. If a tax agent has a number of MNE groups to request deferrals for, deferrals for each MNE group must be submitted using a separate form.

Before submitting a deferral request

Ensure that you send your request before the due date and include sufficient reasons for your deferral request. Each group entity's deferral request will be considered separately, as there may be different reasons for the request for each group entity.

As outlined in PCG 2025/4 Global and domestic minimum tax lodgment obligations – transitional approach, during the transition period (fiscal years commencing on or before 31 December 2026 and ending on or before 30 June 2028) we will consider whether reasonable measures have been taken when assessing a deferral request. We will contact you in relation to the outcome of your request.

Submitting lodgment deferral – tax agents

Tax agents cannot lodge the Pillar Two lodgment deferral via the existing lodgment deferral form in Online services for agents. The completed Combined Global and domestic minimum tax return lodgment deferral request form must be sent to us using practice mail:

• open a New message
• select the Topic: Global and domestic minimum tax
• select the Subject: Request for lodgment deferral
• select the appropriate option in the Enquiry type drop-down menu
• attach the completed form
• select the Declaration, then send.

Submitting lodgment deferral – DLE or group entity

Members of an in-scope MNE group (either the DLE or the individual group entities) can submit the Combined Global and domestic minimum tax return lodgment deferral request form via Online services for business using secure mail:

• open a New message
• select the Topic: Global and domestic minimum tax
• select the Subject: Request for lodgment deferral
• select the appropriate option in the Enquiry type drop-down menu
• attach the completed form
• select the Declaration, then send.

If you do not have access to Online services for business then contact us through the Pillar Two mailbox at Pillar2Project@ato.gov.au. (Do not attach the deferral request form to the email as it is not a secure channel. We will provide Kiteworks secure file transfer details.)

If a lodgment deferral is not granted

If a lodgment deferral is not granted for a particular group entity, but other group entities are granted a deferral, then the group entity which was not granted a deferral must lodge its return separately.

If a DLE is lodging on the group's behalf, it must remove the group entity from the group return. This arrangement is only relevant in this fiscal year. In the following fiscal year, the DLE (or a different DLE if nominated) may lodge for the whole group again.

If a lodgment deferral is not granted – suspension of lodgment enforcement action

We usually consider a suspension of lodgment enforcement action when the reasons given for the lodgment deferral request are not sufficient to allow a deferral or where a deferral is not applicable.

We may agree to suspend lodgment enforcement action during the transition period by not undertaking compliance action on a specific overdue lodgment for a period of time.

Generally, a suspension will not be granted for a period greater than 4 weeks. Refer to PS LA 2011/15 for a list of matters we consider when deciding whether to suspend lodgment enforcement action.

You can apply for a suspension through:

• Online services for business using secure mail
  • open a New message
  • select the Topic: Global and domestic minimum tax
  • select the Subject: Request for lodgment deferral
• Online services for agents using practice mail
  • open a New message
  • select the Topic: Global and domestic minimum tax
  • select the Subject: Request for lodgment deferral
• the Pillar Two mailbox at Pillar2Project@ato.gov.au.

A letter informing you of the outcome will be sent to you if:

• a lodgment deferral or suspension of lodgment enforcement action is not granted, or
• we choose to suspend lodgment enforcement action in lieu of granting a lodgment deferral.

If a lodgment deferral is granted, the new lodgment date will show in Online services for business or Online services for agents.

Payment deferral

Requests for payment deferrals are made separately to lodgment deferral requests, although they can be made at the same time.

You can request a payment deferral if:

• there are, or have been, exceptional or unforeseen circumstances beyond their control
• the exceptional or unforeseen circumstances must be consistent with those outlined in Practice Statement PS LA 2011/14 General debt collection powers and principles.

Combined global and domestic minimum tax return payment deferral request form

Download the Combined global and domestic minimum tax return payment deferral request form (NAT 75813), XLSX, 112KB)This link will download a file and provide details of the exceptional or unforeseen circumstances.

Submitting payment deferral – tax agents

Tax agents cannot lodge the Pillar Two payment deferral via the existing payment only deferral application form in Online services for agents. The completed Combined global and domestic minimum tax return payment deferral request form must be sent to us using practice mail:

• open a New message
• select the Topic: Global and domestic minimum tax
• select the Subject: Request for payment deferral
• select the appropriate option in the Enquiry type drop-down menu
• attach the completed form
• select the Declaration, then send.

Submitting payment deferral – DLE or group entity

Members of an in-scope MNE group (either the DLE or the individual group entities) who are not lodging through a tax agent, can submit the payment deferral request form via Online services for business using secure mail:

• open a New message
• select the Topic: Global and domestic minimum tax
• select the Subject: Request for payment deferral
• select the appropriate option in the Enquiry type drop-down menu
• attach the completed form
• select the Declaration, then send.

If you do not have access to Online services for business, then contact us through the Pillar Two mailbox at Pillar2Project@ato.gov.au. (Do not attach the deferral request form to the email as it is not a secure channel. We will provide Kiteworks secure file transfer details.)

If there is a DLE appointed for the MNE group, it is important that the DLE details are also set out in the form (not just the entities on behalf of which the DLE is lodging).

You will be contacted in relation to the outcome of your request if the payment deferral is not granted. Otherwise, the new payment date will show in Online services for business or Online services for agents.

GIR or foreign lodgment notification – suspend lodgment enforcement action

We cannot defer lodgment of the GIR or foreign lodgment notification. We may, however, agree to suspend lodgment enforcement action during the transition period by not undertaking compliance action on overdue lodgments for a period of time.

You can apply for a suspension through:

• Online services for business using secure mail
  • open a New message
  • select the Topic: Global and domestic minimum tax
  • select the Subject: Request for lodgment deferral
• Online services for agents using practice mail
  • open a New message
  • select the Topic: Global and domestic minimum tax
  • select the Subject: Request for lodgment deferral
• the Pillar Two mailbox at Pillar2Project@ato.gov.au.

Generally, a suspension will not be granted for longer than 4 weeks.

An automatic 30-day suspension will apply to any foreign lodgment notification for the fiscal year commencing in 2024, aligning with the 30-day deferral period for the AIUTR and DMTR.

Amendments

You may need to lodge an amended CGDMTR if you have made a mistake or forgotten to include an amount in relation to the CGDMTR.

Not all errors or adjustments require correcting a CGDMTR. For example, there is no need to amend an assessment if the error does not affect the amount of a top-up tax liability. If you would like to correct a GIR, this can be done in respect of any error, not just ones which affect the top-up tax liability.

Amendments can only be made by the original lodging entity. For example, a DLE lodges the CGDMTR on behalf of all the group entities in Australia. It is subsequently discovered that information in the CGDMTR relating to 2 of the group entities requires amending. In this case, only the DLE can amend the CGDMTR on behalf of these 2 group entities, because it had lodged the original CGDMTR for them.

You cannot amend the following information that was provided in the original CGDMTR:

• capacity of lodging entity; that is, switching from a group entity to DLE or DLE to group entity
• adding or removing a group entity
• identifiers of the lodging entity including TFN/ABN/ARN and name
• identifiers of group entities including TFN/ABN/ARN, name and business address
• the reporting period of the return.

All validations applicable on the original are applicable on the amendment.

After lodging the amended CGDMTR, the lodging entity will receive a lodgment success notification and a transaction ID. An amended notice of assessment and statement of account (if applicable) will be issued. The relevant group entity can make a payment if a liability occurs as a result of the amendment.

For further information, see Amending a global and domestic minimum tax assessment and GIR.

Period of review

4-year period of review

A 4-year period of review applies where we may amend global and domestic minimum tax assessments. This period of review may be extended or refreshed. After the period of review ends, an amendment will only be made by us in limited circumstances:

• For assessments of Australian IIR/UTPR tax, the 4-year period starts on the later of
  • the day the GIR is given to the Commissioner
  • the day the AIUTR is given to the Commissioner.
• For assessments of Australian DMT tax, the 4-year period starts on the later of
  • the day the GIR is given to the Commissioner
  • the day the DMTR is given to the Commissioner.

The period of review may be extended by a Federal Court of Australia order or if the taxpayer agrees to a written request by the Commissioner.

When is the GIR given to the Commissioner

The GIR is generally considered given to the Commissioner:

• if lodged in Australia, on the date it is lodged
• if lodged on time with a foreign government agency in accordance with section 127-20 in Schedule 1 to the TAA, on the date it is given to the foreign government agency.

The foreign government agency that the GIR is lodged with must have a QCAA with Australia.

Penalties

What administrative penalties can apply

The existing uniform penalty provisions contained in Schedule 1 to the TAA apply, with base penalty amounts similar to those imposed for significant global entities. This means, for example:

• penalties for failure to lodge on time, which can apply to entities that do not lodge an approved form by the due date. The base penalty amount is multiplied by 500.
• penalties for false and misleading statements or for taking a position that is not reasonably arguable. The base penalty amount is doubled.

In addition, an administrative penalty can apply for failing to keep records about the global and domestic minimum tax.

OECD guidance on penalties

The OECD has released guidance on transitional penalty relief, which outlines that administrators should consider providing a soft landing for MNE groups during a transition period.

This includes recommending administrators consider not applying penalties or sanctions in connection with the filing of the GIR during the transition period where an MNE group has taken 'reasonable measures' to ensure the correct application of the GloBE Rules. 'Reasonable measures' is not defined and should be understood in light of each jurisdiction's existing rules and practices.

ATO guidance on penalties

We have published Practical Compliance Guideline PCG 2025/4 Global and domestic minimum tax lodgment obligations – transitional approach, outlining:

• 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.

We have also published minor updates to existing ATO guidance products relating to the administration of penalties for the global and domestic minimum tax, including to:

• MT 2008/1 Penalty relating to statements: meaning of reasonable care, recklessness and intentional disregard
• MT 2008/2 Shortfall penalties: administrative penalty for taking a position that is not reasonably arguable
• MT 2012/3 Administrative penalties: voluntary disclosures
• PS LA 2005/2 Penalty for failure to keep or retain records
• PS LA 2011/15 Lodgment obligations, due dates and deferrals
• PS LA 2011/19 Administration of the penalty for failure to lodge on time
• PS LA 2012/4 Administration of the false or misleading statement penalty – where there is no shortfall amount
• PS LA 2012/5 Administration of the false or misleading statement penalty – where there is a shortfall amount.

Record keeping

The legislation inserts Subdivision 382-C in Schedule 1 to the TAA which provides record keeping requirements on the Australian global and domestic minimum tax.

Broadly, the provision requires an Australian group entity, as well as GloBE JVs and GloBE JV subsidiaries, of an MNE group, to keep records that fully explain whether it has complied with the global and domestic minimum tax legislation. This includes, but is not limited to, all records that explain and show the basis of every disclosure in the GIR, AIUTR and DMTR lodged or exchanged with the Commissioner.

Excluded entities, which may not have an obligation to lodge, are still required to keep records relating to their status as an excluded entity.

Entities that are exempt from lodgment obligations under the legislative instrument are still required to keep records showing why they qualified for the exemption for a fiscal year.

Records must be kept in writing in English, or in a format that is readily accessible and convertible to English and must enable the entity's liability to top-up tax to be readily determined.

Records must be kept until either:

• the end of 8 years after those records were prepared or obtained
• 8 years after the completion of the transactions or acts to which those records relate
• the end of the period of review for an assessment to which those records relate (if extended), whichever is the later.

Australian record keeping requirements for the GIR

As part of the requirement to keep records that fully explain whether you have complied with the global and domestic minimum tax legislation, you are required to keep records that support the disclosures in the GIR. This is notwithstanding that the UPE or DFE of the MNE group may lodge the GIR with a foreign government agency.

The records required to be kept are dependent on the information required to be provided under the dissemination approach, agreed upon by the OECD Inclusive Framework. The dissemination approach sets out which sections of the GIR are to be distributed to each country based on the MNE group's structure and the requirements of the rule order. More specifically, the UPE country receives the complete GIR, countries with taxing rights receive the detailed calculations for those jurisdictions in which it has taxing rights in relation to, and all countries receive the corporate structure. Based on this, the ATO should receive the following in respect of the GIR:

• Section 1: general information section, such as the group's corporate structure and summary information
• Section 2: jurisdictional sections relating to safe harbours and exclusions where Australia has taxing rights (including Australia itself)
• Section 3: jurisdictions sections providing detailed ETR and top-up tax computations for those jurisdictions in respect of which Australia has taxing rights (including computations in relation to Australia itself which provides the computations for Australian Domestic Minimum Tax)
• the whole GIR where there is an Australian UPE.

Broadly, this means records must be kept for all disclosures in the GIR in relation to overseas jurisdictions where Australia has taxing rights.

Where there is a foreign UPE and Australia does not have taxing rights for an overseas jurisdiction, records must be kept that support that Australian constituent entity has no IIR/UTPR taxing rights as per the agreed rule order. Records must still be kept for all detailed disclosures in the GIR in relation to Australia itself.

Records must also be kept in relation to the MNE group structure regardless of whether Australia has taxing rights over a foreign jurisdiction.

Where there is an Australian UPE, records must be kept for all disclosures in the GIR.

More information

For more information, see:

• Combined global and domestic minimum tax return (PDF, 744KB)This link will download a file for a Group Entity (GE) – sample only
• Combined global and domestic minimum tax return (PDF, 814KB)This link will download a file for a Designated Local Entity (DLE) – sample only
• Online services for agents user guide
• Online services for business user guide
• OECD GloBE RulesExternal Link
• GloBE Information Return (January 2025)External Link – update to version released July 2023
• GloBE Information Return (Pillar Two) XML SchemaExternal Link
• GloBE Information Return (Pillar Two) Status Message XML Schema (PDF, 2.2MB)External Link