Australia will waive local GIR lodgment requirements and hold off on penalties for in-scope MNE groups that file on time in another 2024 implementing jurisdiction listed in the OECD annexe, provided no activated exchange relationship exists with Australia and a foreign lodgment notification has been submitted under the CGDMTR.
The Australian Taxation Office (ATO) has updated its guidance on the Global and Domestic Minimum Tax and Lodging, Paying and Other Obligations for Pillar Two on 26 May 2026.
The updates incorporate the OECD’s common understanding released on 18 May 2026 regarding the waiver of penalties and the non-enforcement of local GIR filing obligations in certain circumstances. The most significant changes in this regard are reflected in the guidance on Lodging, Paying and Other Obligations for Pillar Two.
2024 fiscal year GIR lodgments
Australia is a 2024 implementing jurisdiction and as such requires in-scope MNE groups to lodge their GIR by 30 June 2026 where their first applicable fiscal year ends on or before 31 December 2024. If lodged overseas it must be lodged in a jurisdiction with a QCAA that is in effect with Australia. However, the OECD’s common understanding may provide relief in certain circumstances.
On 18 May 2026, the OECD announced its release of the Global Minimum Tax: Support for Central GloBE Information Return Filing and Exchange (2024 Reporting Fiscal Year). This outlines the common understanding of Australia and other 2024 implementing jurisdictions to support central filing and exchange of GIR information.
In line with the OECD common understanding, we will not request local lodgment of the GIR in Australia before the relevant GIR exchange deadline and not impose penalties that may otherwise be applicable, if at the time of the GIR lodgment due date all the following apply:
- There is no QCAA in effect between Australia and the foreign jurisdiction in which the GIR is lodged because there is no activated exchange relationship between Australia and the foreign jurisdiction.
- The GIR is lodged on time in a 2024 implementing jurisdiction listed in the Annexe of Global Minimum Tax: Support for Central GIR filing and Exchange (2024 Reporting Fiscal Year).
- A foreign lodgment notification, contained in the CGDMTR, has been lodged.
Earlier, the OECD released administrative guidance on 18 May 2026 to help multinational groups manage the Pillar Two GIR filing requirements ahead of the 30 June 2026 deadline. Under a common understanding agreed among 2024 implementing jurisdictions, penalties will be waived and local filing requirements suspended where a group centrally files its GIR in any jurisdiction on the published list by the applicable deadline, and submits a GIR notification in the local jurisdiction within the required timeframe.
The relief is designed to address practical concerns around portal availability and cross-border filing coordination. However, it is not unconditional — if the centrally filed GIR has not been properly exchanged between the relevant tax authorities by 31 December 2026, implementing jurisdictions retain the right to enforce local filing obligations and impose penalties. The end-of-year exchange deadline effectively acts as the backstop that determines whether the transitional flexibility holds.
