Australia’s laws related to the Pillar Two minimum tax, Public Country-by-Country (PCbC) reporting requirements, and capital gains withholding received Royal Assent on 10 December 2024.

Pillar Two global minimum tax law

The Pillar Two global minimum tax law (Taxation (Multinational—Global and Domestic Minimum Tax) Imposition Bill 2024) introduces Pillar Two top-up taxes in Australia, including the Domestic Minimum Tax (DMT), Income Inclusion Rule (IIR), and Undertaxed Profits Rule (UTPR). The DMT and IIR taxes start from fiscal years beginning on or after 1 January 2024, for multinational groups with over EUR 750 million in annual global revenue. The UTPR tax will apply from fiscal years starting on or after 1 January 2025.

Earlier, the Australian Senate passed the Taxation (Multinational—Global and Domestic Minimum Tax) Imposition Bill 2024 on 26 November 2024 following the legislation’s endorsement by the House of Representatives in August 2024.

Public country-by-country (PCbC) reporting

Australia’s PCbC reporting was introduced in a new legislation –  Treasury Laws Amendment (Responsible Buy Now Pay Later and Other Measures) Bill 2024 – in Parliament on 5 June 2024.

Earlier, the parliament passed a legislation, on 29 November 2024 mandating all multinational groups to publicly disclose country-by-country (PCbCR) tax information starting 1 July 2024.

Capital gains withholding bill

The Treasury Laws Amendment (2024 Tax and Other Measures No. 1) Bill 2024 simplifies tax processes for small businesses and improves compliance with capital gains withholding for foreign residents. The key change includes increasing the foreign resident capital gains withholding rate from 12.5% to 15%.  It also removes the current AUD 750,000 threshold for withholding on transactions involving taxable Australian real property or indirect Australian property interests with company title.

The Act allows small and medium businesses to request tax assessment amendments up to four years from the current two years after receiving notice, starting from income years on or after 1 July 2024.

These changes apply to relevant CGT assets acquired on or after 1 January 2025.

Earlier, the bill was presented in the parliament on 12 September 2024.