The Australian Taxation Office has released new guidance to help multinational groups navigate their Pillar Two obligations, covering everything from lodgment returns and fiscal year rules to interactions with Australia's foreign income tax offset and consolidation regimes.
The Australian Taxation Office (ATO) released the updated guidance on Lodging, paying and other obligations for Pillar Two on 12 March 2026. The updated guidance on the Global and domestic minimum tax is designed to help multinational enterprise groups understand and prepare for their Pillar Two obligations.
The updates provide additional information to ATO’s existing guidance, covering:
- lodgment of the GloBE Information Return (GIR) and the combined global and domestic minimum tax return (CGDMTR)
- lodgment deferrals
- misaligned fiscal years
- legislative instrument examples
- ATO practical administrative approaches
- Pillar Two interactions with Australian foreign income tax offset (FITO) rules.
The ATO is also organising a Pillar Two information session in April 2026. This session will allow attendees to hear from Pillar Two experts and Treasury about topics, such as the latest Pillar Two developments. It will cover the side-by-side solution, system updates, lodgment obligations and lodgment specifics, and record keeping. This will be the most practical session yet.
The ATO has also updated guidance on:
Pillar Two interactions with other provisions: Australia’s implementation of the Global Anti-Base Erosion Model Rules (GloBE Rules) includes consequential amendments to Australia’s income tax law to clarify its interaction with Pillar Two. The amendments are included in the Multinational—Global and Domestic Minimum Tax (Consequential) Act 2024(Consequential Act). In particular, the Consequential Act includes amendments to specific Australian cross-border tax provisions. These include rules concerning foreign income tax offsets, controlled foreign companies, hybrid mismatches and foreign hybrids.
Specific issues for Pillar Two: This includes specific issues identified by stakeholders via consultation and other channels not covered in other Pillar Two content.
For global and domestic minimum tax purposes, the term “fiscal year” generally refers to the accounting period for which the ultimate parent entity (UPE) of a multinational enterprise group (MNE group) prepares its consolidated financial statements.
If the UPE does not prepare consolidated financial statements, the fiscal year of the UPE will be the calendar year instead. As such, a constituent entity’s own accounting period does not determine its fiscal year for Pillar Two purposes, only the UPEs. Lodgment due dates for Australian group entities are also determined using the fiscal year of the UPE.
Tax consolidated group lodgments for Pillar Two: This includes how Pillar Two lodgment obligations apply to tax consolidated groups. The Australian global and domestic minimum tax introduces 4 new lodgment obligations:
- GloBE Information Return (GIR)
- Foreign lodgment notification
- Australian IIR/UTPR Tax Return (AIUTR)
- Australian DMT Tax Return (DMTR).
Each group entity located in Australia has an obligation to lodge either a GIR or foreign lodgment notification (where the GIR is lodged overseas). This includes subsidiary members of a tax consolidated group.
Each group entity must also lodge an AIUTR or DMTR, unless its circumstances qualify for a lodgment exemption. Under the Legislative Instrument LI 2025/28 Taxation Administration (Exemptions from Requirement to Lodge Australian IIR/UTPR Tax Return and Australian DMT Tax Return) Determination 2025, subsidiary members of a tax consolidated group may be exempt from lodging the AIUTR or the DMTR, or both the AIUTR and DMTR, depending on their circumstances.
When and how the Pillar Two rules apply: This discusses how the Pillar Two global and domestic minimum tax rules work and when and to whom they apply.
The Australian global and domestic minimum tax implements the Global Anti-Base Erosion Model Rules (GloBE Rules) through primary and subordinate legislation, referred to together as the Minimum Tax law.
The primary legislation includes the:
- Taxation (Multinational—Global and Domestic Minimum Tax) Act 2024 (Minimum Tax Act)
- Taxation (Multinational—Global and Domestic Minimum Tax) Imposition Act 2024 (Minimum Tax Imposition Act)
- Treasury Laws Amendment (Multinational—Global and Domestic Minimum Tax) (Consequential) Act 2024 (Minimum Tax Consequential Act)
The subordinate legislation includes the:
- Taxation (Multinational–Global and Domestic Minimum Tax) Rules 2024 (Australian Minimum Tax Rules)
- Taxation Administration (Exemptions from Requirement to Lodge Australian IIR/UTPR Tax Return and Australian DMT Tax Return) Determination 2025
- Taxation (Multinational–Global and Domestic Minimum Tax) (Qualified GloBE Taxes) Determination 2025
The Minimum Tax law is to be interpreted in a manner consistent with specific Organisation for Economic Co-operation and Development (OECD) guidance materials for GloBE. Such materials include the GloBE Model Rules, commentary, and agreed administrative guidance.
Pillar Two interactions with consolidation: This guidance is about how the Pillar Two rules apply to consolidated groups. The Pillar Two rules apply to multinational enterprise groups (MNE groups). They contain certain interactions with existing corporate income tax grouping rules. The OECD guidance materials adopt broad definitions for tax consolidated groups designed to capture a range of local tax consolidation regimes, including Australia’s tax consolidation regime.
