This guide covers Australia’s Pillar Two filing processes including the separate local GIR XML filing, the foreign lodgment notification, and the Combined Global and Domestic Minimum Tax Return (CGDMTR), including the Australian IIR/UTPR tax return and Australian DMT tax return. It also flags the main ATO validation rules and the software/API points that matter if you are building or testing a filing process.
| Obligation | When it applies | How it is filed | Practical point |
|---|---|---|---|
| Local GIR | Where Australia expects the GIR to be lodged with the ATO | OECD GIR XML filed through the ATO file-transfer channel | Separate from the domestic approved-form return |
| Foreign lodgment notification | Where the GIR is lodged outside Australia and exchange into Australia is expected | Included inside the CGDMTR | Captures UPE/DFE/jurisdiction/GIR date exchange-of-information data |
| AIUTR | Where an Australian IIR or UTPR amount must be assessed | Included inside the CGDMTR | UTPR only applies from fiscal years starting on or after 1 January 2025 |
| DMTR | Where Australian Domestic Top-up Tax must be assessed | Included inside the CGDMTR | Nil amounts still need to be reported where the indicator is true |
Australia has split Pillar Two compliance into two separate filing tracks.
The first track is the GloBE Information Return (GIR). If an Australian entity has to lodge the GIR locally, it is lodged as an OECD GIR XML file with the ATO through the file transfer channel. The ATO has published an Australian GIR software package and validation-rule set for the 2026 OECD GIR, and its software-developer site says the GIR message structure should always be used with the OECD schema.
The second track is the Combined Global and Domestic Minimum Tax Return (CGDMTR). This is Australia’s domestic approved-form return. It bundles:
-the foreign lodgment notification (used when the GIR is lodged outside Australia),
-the Australian IIR/UTPR tax return (AIUTR), and
-the Australian DMT tax return (DMTR).
That split matters in practice. A group can have a local GIR filing obligation, a foreign-lodgment notification obligation, Australian DMT/IIR/UTPR tax-return obligations, or more than one of those at the same time. The domestic return is not a substitute for the GIR, and the GIR is not a substitute for the domestic assessment return.
The ATO’s published timetable follows the staged Australian commencement dates:
-Australian IIR and Australian DMT apply for fiscal years starting on or after 1 January 2024.
-Australian UTPR applies for fiscal years starting on or after 1 January 2025.
For the first fiscal year in scope, the filing due date is 18 months after year end. For the second and later fiscal years, the filing due date is 15 months after year end. The ATO applies the same 18-month/15-month timetable across the GIR, the foreign lodgment notification, the AIUTR and the DMTR. Amounts payable under the AIUTR or DMTR are due on the same timetable: the last day of the 18th month after year end for the first year, and the last day of the 15th month after year end thereafter.
For a 31 December 2024 year end, that means the first Australian filings generally fall due at the end of June 2026.
The first issue is whether the GIR will be lodged in Australia or lodged in another jurisdiction and exchanged into Australia.
If the GIR is lodged locally with the ATO, either each Australian Group Entity or a Designated Local Entity (DLE) can lodge it. Where the GIR is lodged locally, there is no need to lodge the foreign lodgment notification with the ATO.
If the GIR is lodged outside Australia by a UPE or DFE, the Australian filing work usually moves into the foreign lodgment notification part of the CGDMTR. The notification tells the Commissioner who lodged the GIR, in which jurisdiction, when it was or will be lodged, and whether Australia will receive it through exchange of information.
The practical fail-safe is also published by the ATO: where there is no operative GIR MCAA or equivalent agreement between Australia and the UPE or DFE jurisdiction, the Australian lodging entity must lodge the GIR in Australia rather than rely on a foreign filing.
Australia currently supports three main domestic channels for the CGDMTR and one separate channel for the GIR.
1. Online services for business
This is the ATO’s direct online channel for businesses. The first online lodgment will automatically create the taxpayer’s Global and Domestic Minimum Tax (GDMT) account and relevant role. One practical limitation is scale: groups lodging through Online services for business or Online services for agents should note the 20-entity limit.
2. Online services for agents
Registered tax agents can lodge for clients through the agent portal.
3. Template/digital channel/APIs
The ATO has also published a CGDMTR template route and a software API route. The template instructions say the completed template must be lodged electronically through the ATO’s secure file sharing platform. For software integrations, the ATO API product supports up to 300 entities in one lodgment.
The GIR XML file is lodged with the ATO using the file transfer facility in Online services for business or Online services for agents. The ATO software-developer site separately publishes the ATO GIR.0001 2026 Package and points users to Bulk Data Exchange (BDE) common information artefacts.
-The CGDMTR can be accessed in Online services for business or Online services for agents.
-For API implementations, the ATO product requires the normal ATO API onboarding steps: client authentication, Access Manager authorisation, sandbox testing, the health-check step, and any API-specific testing before production access is granted.
-For GIR/BDE testing, the ATO also publishes a File transfer test facility. Access requires a registration form, and the facility returns a validation report after file checks.
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