The session focused on the engagement with multinational enterprise (MNE) groups that may be in-scope of the measure, and with tax advisers providing specialist services around Pillar Two. 

The Australian Taxation Office (ATO) has released a summary, on 24 September 2025, of the inaugural Pillar 2 information session held in August 2025.

Pillar Two: August session recap and what’s next

Key updates on what to expect in the coming months for MNEs and advisers on Pillar Two global and domestic minimum tax.

ATO held its first open information session in August about the implementation of a global and domestic minimum tax (Pillar Two). The focus was on engaging with multinational enterprise (MNE) groups that may be in-scope of the measure, and with tax advisers providing specialist services around Pillar Two. This ongoing engagement will help the ATO to develop the guidance and support that it will provide for this measure.

The information session covered:

  • An overview of the Pillar Two rules
  • Australia’s legislation and guidance
  • Key taxpayer obligations
  • How ATO is supporting the market and what’s coming next.

Where to find information

Many of the topics that attendees raised at the open information session are already addressed in the web content, including those covered below. ATO will continue to update their website and expand the guidance.

Permanent establishments

One can visit When and how the Pillar Two rules apply to learn how the Pillar Two rules apply to permanent establishments in Australia.

GloBE information return (GIR)

It’s expected that Australia will sign the GIR Multilateral Competent Authority Agreement; however, this is a matter for the Treasury, not the ATO. ATO will continue to update their web content about the GIR in the coming months.

Lodgment requirements

One of the main topics that attendees raised was lodgment obligations. In the web content, you can find details on:

  • Who can lodge on behalf of a permanent establishment
  • Lodging the GIR, including if the constituent entity applies for safe harbour
  • Lodging information for constituent entities that meet the transitional safe harbour
  • Lodging requirements for Australian entities where there are multiple subsidiaries in Australia for the one MNE group
  • Nominating a designated filing entity included in the foreign lodgment notification.

Legislative instrument

Since the information session, ATO has released a draft LI 2025/D17. It sets out the circumstances where a group entity of an in-scope multinational enterprise (MNE) does not need to lodge the Australian IIR/UTPR Tax Return and the DMT Tax Return for a fiscal year.

What’s next?

ATO will be holding another Pillar Two open information session in November and will share more details, including how to register, closer to the date. ATO will also regularly update its website with expanded guidance, including information on safe harbours and consolidations.