The Australian Taxation Office has released guidance on 19 May 2026 detailing how multinational enterprises can create Pillar Two accounts for filing Global Minimum Tax returns. Most in-scope entities will have accounts automatically created upon their first lodgment, though some may need to request account creation in advance when nominating separate tax agents for Pillar Two obligations.
The Australian Taxation Office (ATO) has published guidance on Pillar Two account and role creation on 19 May 2026.
In March, the ATO published information about how MNE groups and their advisers could prepare for Pillar Two (global and domestic minimum tax) lodgments and obligations. This included information about Pillar Two registrations.
For most in-scope entities, registration for Pillar Two is generally not required prior to the first lodgment of a GloBE Information Return (GIR) and Combined global and domestic minimum tax return (CGMDTR). Upon lodgment of the first CGDMTR, the ATO automatically creates a Global and Domestic Minimum Tax (GDMT) account and relevant role in its system. A GIR and CGDMTR can be lodged online through either:
- Online services for business – provided a designated local entity (DLE) or group entity has an account
- Online services for agents – an agent can lodge on the entity’s behalf
- business software – if it has the required application programming interface (contact the relevant Digital Service Provider to check).
In some situations, a GDMT account and role may need to be created before lodgment. This can apply where an entity needs to nominate a tax agent specifically for Pillar Two (where they differ from the client-level agent).
How to request a GDMT account and role creation
This option should only be used if a CGDMTR has not already been lodged online. To avoid processing delays when lodging a request, the following must be provided:
- full entity details
- the fiscal year start date
- fiscal year end date.
The fiscal year should be the same as the ultimate parent entity’s (UPE).
If the lodgment is being made by a DLE, and a Pillar Two agent needs to be nominated, only the DLE needs to request a GDMT account and role. All group entities included in the lodgment on behalf of which the DLE is lodging do not need to request an account and role creation. Likewise, when a standalone group entity makes the lodgment and the above circumstances apply, only the group entity needs to request the GDMT account and role creation.
A Pillar Two account and role creation can be requested by lodging a request to create a GDMT account through either:
- Online services for business using secure mail
- open a New message
- select the Topic: Global and domestic minimum tax
- select the Subject: Request for account and role
- in the portal message text, provide full entity details and the fiscal year end date and fiscal year start date for the lodgment in the request
- Online services for agents using practice mail (only agents already linked at the client level can make this request)
- open a New message
- select the Topic: Global and domestic minimum tax
- select the Subject: Request for account and role
- in the portal message text, provide full entity details, including client identifiers and the fiscal year end date and fiscal year start date for the lodgment in the request.
Entities that cannot access the ATO’s online services and do not have a current client-level agent must contact the ATO:
- phone 13 28 66 (businesses)
- email the Pillar2Project@ato.gov.au
Full entity details and the fiscal year end date and fiscal year start date for the lodgment must be provided in the request.
Next steps
After the ATO creates the GDMT account and role, the entity can nominate an agent. Agents linked at the client level can then lodge the CGDMTR. Entities should remember to inform their agent once nominated, as agents will not be automatically notified.
Agents have 28 days from the date of nomination to add the entity as a client. After that, the nomination expires.
Tax agents may also remove client to agent linking in Online services for agents, following the remove client instructions in the ATO’s user guide.
If follow-up is required regarding GDMT account and role creation, the original Portal Receipt ID and full entity details, including the client identifier, should be included in the request.
