Australia has expanded its recognition of compliant international tax regimes through a new determination gazetted on 20 March 2026, adding jurisdictions confirmed by the OECD as meeting global minimum tax standards. The amendment aligns Australia's framework with the latest OECD records of qualifying global anti-base erosion taxes, building on the original 2025 determination that established a 15% minimum tax rate for large multinationals operating across 32 jurisdictions.
Australia’s government has gazetted the Taxation (Multinational—Global and Domestic Minimum Tax) (Qualified GloBE Taxes) Amendment (Measures No. 1) Determination 2026 on 20 March 2026, which amends the Taxation (Multinational—Global and Domestic Minimum Tax) (Qualified GloBE Taxes) Determination 2025 and aligns it with the OECD’s central record of jurisdictions that have qualifying global anti-base erosion (GloBE) taxes.
The legislation identifies additional jurisdictions with a qualified income inclusion rule (IIR), a qualified domestic minimum top-up tax (QDMTT), or those recognised by the Minister as meeting QDMTT safe harbour requirements for a given fiscal year.
These jurisdictions were confirmed by the OECD as having implemented IIR and DMTT rules with transitional qualifying status in August 2025 and January 2026.
Qualified tax regimes across multiple jurisdictions
The determination identifies qualified Income Inclusion Rules (IIRs) and Qualified Domestic Minimum Top-up Taxes (QDMTTs) across 32 jurisdictions. Australia’s own IIR and QDMTT received qualified status for fiscal years beginning on or after 1 January 2024.
Most European Union countries, including France, Germany, Belgium, and the Netherlands, qualified for fiscal years starting on or after 31 December 2023. Asian nations such as Japan (1 April 2024), Korea (1 January 2024), and Vietnam (1 January 2024) also achieved qualified status, while Guernsey’s qualification takes effect for fiscal years beginning 1 January 2025.
Safe harbour provisions for domestic taxes
The determination grants QDMTT Safe Harbour status to 33 jurisdictions, allowing multinational groups to avoid double taxation when operating in these countries. This status applies to the same fiscal year dates as the QDMTT qualifications.
Barbados, the Slovak Republic, and Switzerland received QDMTT qualification and Safe Harbour status despite not having qualified IIRs listed in the determination. This reflects their adoption of domestic minimum taxes without implementing full income inclusion rules.
Implementation under the Globe Rules Framework
The determination operates under the Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024, which incorporates the OECD’s Global Anti-Base Erosion (GloBE) Rules. These rules establish a 15% global minimum tax rate for multinational enterprises with revenue exceeding EUR 750 million.
The instrument took effect the day after registration and will apply to current and future fiscal years as specified for each jurisdiction.
