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GloBE Country Guide: Australia

Summary

Status Enacted Law
LawOn August 27, 2025, the Australian Taxation Office issued a draft legislative instrument for consultation (the ‘Taxation Administration (Exemptions from Requirement to Lodge Australian IIR/UTPR tax return and Australian DMT tax return Determination 2025’) ). This outlines situations when entities within the scope of the Pillar 2 GloBE rules do not need to file an Australian DMT Return or an IIR/UTPR Return.

On July 4, 2024, draft legislation was submitted to Parliament. This includes the Taxation (Multinational-Global and Domestic Minimum Tax) Bill 2024, Taxation (Multinational-Global and Domestic Minimum Tax) Imposition Bill 2024 and the Treasury Laws Amendment (Multinational-Global and Domestic Minimum Tax) (Consequential) Bill 2024.These were passed by Parliament on November 26, 2024 and received Royal Assent on December 10, 2024:

Treasury Laws Amendment (Multinational—Global and Domestic Minimum Tax) (Consequential) Act 2024

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

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

On March 21, 2024, the Australian Treasury released draft legislation and draft rules as part of a consultation to implement the Pillar Two GloBE Rules. This includes an IIR, UTPR and a domestic minimum tax. Explanatory notes were also issued.

On December 23, 2024, Australia issued the Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024 to provide for the detailed application of the Pillar 2 GloBE rules in Australia.

On July 16, 2025, the ATO released a Draft Practical Compliance Guideline on the transitional approach to filing obligations for the IIR,UTPR and QDMTT.
Effective DateFinancial years beginning on or after January 1, 2024
IIRYes (2024)
UTPRYes (2025)
QDMTTYes (2024)
Filing DeadlinesStandard
Safe HarboursTransitional CbCR Safe Harbour, the Transitional UTPR Safe Harbour, the QDMTT Safe Harbour and the Simplified calculations for Non-Material Constituent Entities Safe Harbour

Contents
  1. Legislation
  2. General
  3. Differences to Model Rules
  4. Qualifying Domestic Minimum Top-Up Tax
  5. Administration and Filing
  6. Penalties

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