GloBE Country Guide: Australia

Summary

Status	Enacted Law
Law	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.
Effective Date	Financial years beginning on or after January 1, 2024
IIR	Yes (2024)
UTPR	Yes (2025)
QDMTT	Yes (2024)
Filing Deadlines	Standard
Safe Harbours	Transitional CbCR Safe Harbour, the Transitional UTPR Safe Harbour, the QDMTT Safe Harbour and the Simplified calculations for Non-Material Constituent Entities Safe Harbour

Legislation
General
Differences to Model Rules
Qualifying Domestic Minimum Top-Up Tax
Administration and Filing
Penalties

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Lee Hadnum

Lee is a qualified Chartered Accountant and Chartered Tax Adviser. A former Senior Tax Analyst at Bloomberg Tax, Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience. Lee's books have been recommended by The Times, The Guardian and The Telegraph.

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