The Australian Taxation Office (ATO) has published new guidance on the Pillar Two minimum tax rules on 16 May 2025.
It now includes:
- Guidance about how the ATO will administer potential amendments to Australian law to address inconsistencies;
- Overview of the mechanics for calculating top-up tax;
- Additional information on how the rules apply, including in respect of specific entities;
- Additional information and examples about filing, payment, and record-keeping obligations;
- How Pillar Two interacts with other provisions.
Earlier, on 23 December 2024, the ATO updated the guidance on the Global and Domestic Minimum tax, which included the subordinate legislation outlining detailed computational rules under the Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024.
