The Australian Taxation Office (ATO) has updated its advice and guidance plans on international issues, including the Pillar Two global minimum tax. This covers Pillar Two lodgment obligations, the ATO’s transitional approach, and updated advice on private rulings and web content.
Title
Global and domestic minimum tax – the implementation of Pillar Two of the OECD/G20 Two-Pillar Solution for multinational businesses in Australia
Purpose
Australia has implemented the Global Anti-Base Erosion Model Rules by introducing a global and domestic minimum tax.
As part of ongoing ATO consultation, we have sought feedback on guidance that will most usefully support implementation of the new measure. We will continue to seek feedback as Australia’s implementation of Pillar Two progresses.
Based on feedback received to date, we have identified 3 priorities for guidance on:
- Pillar Two lodgment obligations and the ATO’s transitional approach
- the ability to seek private rulings and the new decline to rule provision for Pillar Two
- other technical and administrative aspects of ATO’s implementation of Pillar Two.
We continue to engage with the Pillar Two Global Domestic Minimum Tax Working Group to seek feedback on additional topics which require guidance. We also encourage stakeholders to contact us if you have any feedback on priority issues for public advice and guidance.
Details of the 3 initial priorities are discussed below.
Expected completion date
To be advised
Contact
Title
Pillar Two lodgment obligations and the ATO’s transitional approach
Purpose
Pillar Two introduces 4 new obligations which entities in in-scope multinational enterprise group may be required to lodge.
A new product will be created which outlines the ATO’s transitional approach and expectations in relation to these new lodgment obligations.
Expected completion date
To be advised
Contact
Pillar2Project@ato.gov.au
Title
Draft update to Taxation Ruling TR 2006/11 Private Rulings
Purpose
Taxation Ruling TR 2006/11 will be updated to provide advice on the ability to obtain private rulings on interpretative issues relating to Pillar Two and on the new Pillar Two decline to rule provision.
Expected completion date
To be advised
Contact
Brendan Wagner, Office of the Chief Tax Counsel
Title
Website guidance on key aspects of the global and domestic minimum tax
Purpose
Web content will provide information on key aspects of the new measure, including:
- when, how and who the Pillar Two rules apply to
- lodging, paying and other obligations for Pillar Two
- Pillar Two interactions with Australian domestic tax laws.
Expected completion date
Mid 2025
Contact
Pillar2Project@ato.gov.au
