A Review of Australia’s Pillar Two filing and payment requirements

On March 12, 2026, the Australian Taxation Office’s issued updated guidance on “Lodging, paying and other obligations for Pillar Two”. 

The ATO identifies four lodgement requirements for Australia’s global and domestic minimum tax regime: the GloBE Information Return (GIR), the foreign lodgement notification, the Australian IIR/UTPR Tax Return (AIUTR) and the Australian DMT Tax Return (DMTR). The GIR is the OECD information return for the MNE group. By contrast, the AIUTR and DMTR are Australian domestic tax returns that activate Australia’s assessment and payment machinery for Pillar Two amounts. The foreign lodgement notification is the Australian notification that must be given where the GIR is lodged overseas rather than locally with the ATO.

The ATO has simplified the filing by combining the foreign lodgement notification, the AIUTR and the DMTR into one domestic form, the Combined Global and Domestic Minimum Tax Return (CGDMTR). The GIR remains separate and must still be lodged on its own. 

Who lodges, and how a DLE changes the process

The default position is that Australian group entities with a relevant obligation must lodge. However, the guidance permits centralised filing through a designated local entity, or DLE. A DLE can be appointed to lodge the GIR, the foreign lodgement notification, and the AIUTR and DMTR on behalf of Australian group entities. The DLE must be a group entity that is GloBE-located in Australia for the fiscal year, be nominated by the relevant Australian group entities for the relevant obligations, and must not be an excluded entity or a permanent establishment. The ATO also says there is no separate nomination form: the DLE is identified in the GIR and the CGDMTR, and the group must keep written records of each entity’s nomination.

The CGDMTR can be lodged through Online services for business, Online services for agents, or API-enabled software. Where a DLE is using ATO online services, the platform can handle up to 20 entities, including the DLE itself. If more than 20 entities must be covered, the group will need to lodge through an API solution, which supports up to 300 entities. The same page also notes that group entities with no lodgement obligation are not counted towards those limits. In practical terms, groups need to decide early whether the Australian filing will be done centrally and, if so, whether the online channel is sufficient or an API route is required.