The Australian Taxation Office (ATO) released instructions on 4 August 2026 for completing the Combined Global and Domestic Minimum Tax Return (CGDMTR), setting out section-by-section guidance on client information, group entity disclosure, GloBE Information Return (GIR) lodgment notification, and payment reference number requirements for multinational enterprise groups within the scope of Pillar Two.
The Australian Taxation Office (ATO) has published updated guidance on 4 August 2026 on Global Anti-Base Erosion (GloBE) joint ventures, including instructions for completing the Combined Global and Domestic Minimum Tax Return (CGDMTR). The expanded guidance aims to help multinational enterprise groups within the scope of Pillar Two understand and comply with their reporting and tax obligations.
This section covers who is actually lodging the CGDMTR and their details. The reporting fiscal year is stated here (matching the UPE’s consolidated accounts period, not necessarily the entity’s tax year), followed by a declaration of whether the lodgment is being made as a standalone group entity or as a designated local entity (DLE) representing others. Once a capacity is selected, the ATO will not permit a switch later. At least one identifier must be provided (TFN or ABN preferred, ARN/TIN as fallback), alongside entity type, associate entity details, and business/postal addresses.
Section 2: Group entities and combined return
Every group entity covered by the return is disclosed here, noting whether a foreign lodgment notification applies to each, and reporting top-up tax amounts (including nil) for each entity. A DLE lodging on behalf of the group must enter this for all entities, not just its own. One detail worth flagging for groups over the cap: those lodging for more than 20 entities cannot use ATO online services and must use third-party software instead. The UTPR does not kick in until fiscal years starting 1 January 2025, so it is absent from current-year reporting.
Section 3: Local and foreign lodgment notification
This is where the GloBE Information Return (GIR) trail gets documented: UPE and DFE details, and where and when the GIR was or will be lodged, whether in Australia directly or overseas by the UPE or DFE. If lodged overseas, confirmation is required that the foreign jurisdiction has an active exchange agreement with Australia — otherwise the GIR must still come to the ATO directly. The section also captures the currency and exchange rate methodology used to convert Australian top-up tax figures to AUD.
The final checkpoint before submission. The ATO pulls together everything entered across client information, group entity details, and GIR lodgment notification into one summary screen for review. Once the return is lodged, it is locked and cannot be edited — only errors can be fixed or amendments made later. Any entity with an amount payable receives its own payment reference number (PRN), which must be used to make that payment.
