The ATO revised its Pillar Two guidance on 4 August 2026, adding detail on GIR lodgment and validation, deregistered entities, and credit transfers, while expanding rules for GloBE joint ventures and DMTR obligations.
The Australian Taxation Office (ATO) has updated its guidance on Lodging, Paying and Other Obligations for Pillar Two on 4 August 2026. The revised guidance introduces new sections covering the lodgment of the GloBE Information Return (GIR), deregistered entities, and credit transfer and refund requests, while also expanding the guidance on GloBE joint ventures.
How to lodge the GIR
The GIR XML file must be lodged through:
Taxpayers with a tax file number (TFN) may nominate a tax agent to lodge the GIR on their behalf. If your tax agent is unable to add you as a client, phone 13 28 66 or email Pillar2Project@ato.gov.au.
When you lodge the GIR XML file, you will receive a message from the channel indicating that your lodgment has been successfully submitted. This does not mean that your lodgment has been accepted in our systems, as it will be subject to further data validation. The data validation process is not immediate.
When the lodgment goes through the data validation process by our internal systems, an email advising the outcome will automatically be sent to the contact email address, if provided at lodgment in the file transfer function. The email you receive will do one of the following:
Confirm that your lodgment has been accepted.
Confirm that your lodgment has been accepted but we have found some errors. Majority of these errors are intended to be alerts to verify the accuracy of the information provided and may not always need amendment of the GIR.
Advise that your lodgment has not been accepted, with details of the errors that led to the lodgment failing validation. The GIR will need to be resubmitted after correcting the critical errors.
If you don’t receive a lodgment confirmation email within seven days of making your lodgment, email Pillar2Project@ato.gov.au.
GloBE joint ventures
GloBE JVs and GloBE JV subsidiaries are not required to separately lodge the GIR or the AIUTR. However, disclosure requirements regarding GloBE JVs and GloBE JV subsidiaries are required in the GIR for applicable MNE groups that hold ownership in GloBE JVs.
GloBE JVs and GloBE JV subsidiaries are required to lodge a DMTR under section 127-55 of the TAA and may be liable to pay domestic minimum tax. Despite the possibility of being part of 2 or more applicable MNE groups, the GloBE JV along with its GloBE JV subsidiaries have one single DMTR lodgment obligation, which can be satisfied in two main ways:
1. Appoint a DLE of one of the broader MNE groups to lodge on their behalf
A GloBE JV of an applicable MNE group and its GloBE JV subsidiaries may appoint a DLE of that applicable MNE group to lodge their DMTRs on their behalf. If an entity is a GloBE JV of two applicable MNE groups for a fiscal year, the GloBE JV and its GloBE JV subsidiaries may only appoint a DLE of one of those groups to lodge their DMTRs.
In filing for the DMTR, the GloBE JV and GloBE JV subsidiaries lodgment due date will be based on the fiscal year of the GloBE JV itself. A GloBE JVs may have a different fiscal year to that of the broader MNE group or MNE groups. In this case, the GloBE JV and GloBE JV subsidiaries should only appoint a DLE with the same fiscal year end to lodge its DMTR.
2. Lodge standalone DMTRs
Alternatively, a GloBE JV and its GloBE JV subsidiaries can choose to lodge their DMTRs separately on a stand-alone basis. This would be required where the fiscal year of the GloBE JV is different to that of the broader MNE group or MNE groups.
For instructions on how to lodge for a GloBE JV or GloBE JV subsidiaries, see CGDMTR Appendix.
The Commissioner’s Legislative Instrument outlines circumstances in which a GloBE JV or GloBE JV subsidiary need not lodge a DMTR.
Taxpayers who are unable to lodge their GloBE JV obligations should email Pillar2Project@ato.gov.au
Deregistered entities
If a company with Pillar Two lodgment obligations has been deregistered, it ceases to exist as a legal entity and can no longer be included in the CGDMTR as a group entity or lodge on a standalone basis. It can still be included in the GIR.
Where the deregistered company has a Pillar Two top-up tax liability, email Pillar2Project@ato.gov.au before lodging the return.
If you have already lodged a CGDMTR and have included a deregistered entity, we may cancel the specific deregistered entity form. You don’t need to take any further action, unless we contact you.
Credit transfer and refund requests
The existing functions to request a transfer of a credit balance between accounts or a refund for an account with a credit balance is not available for the GDMT account in Online services for business or Online services for agents.
To request a credit transfer or refund, phone 13 28 66 (business) or 13 72 86 (registered tax agents), or email Pillar2Project@ato.gov.au.
