On 11 August 2023, the Australian Taxation Office (ATO) officially initiated targeted public consultation regarding the adoption of Pillar 2 global minimum tax rules. Consultation is being undertaken in a phased approach:
- Phase 1 with industry groups and their members (July – August 2023).
- Phase 2 with mid-tier firms (August – October 2023).
- Phase 3 with large advisory firms (September – November 2023).
The 15% global minimum tax and 15% domestic minimum tax will apply to large multinationals with annual global revenue of EUR750 million (approximately $1.2Â billion) or more. This measure is not yet law and new legislation will be introduced.
In scope multinational groups will need to:
- provide new information to adhere to the reporting obligations under the global minimum tax and domestic minimum tax (this may require new systems)
- lodge a GloBE Information Return (GIR)
- the GIR will need to be lodged 18 months after the first-year end (15Â months for subsequent years).
- the OECD have published GIR requirements.
The start dates for the:
a) 15% global minimum tax for large multinational enterprises will occur over two years with the
-
- Income Inclusion Rule to apply to income years starting on or after 1 January 2024, and
- Undertaxed Profits Rule to apply to income years starting on or after 1 January 2025.
b) 15% domestic minimum tax to apply to income years starting on or after 1 January 2024.