The consultation is set to conclude on 21 November 2025.
Regfollower Desk
The Australian Treasury has opened a consultation on the draft Taxation (Multinational—Global and Domestic Minimum Tax) Amendment (2025 Measures No. 1) Rules 2025 on 27 October 2025.
These amendments revise certain provisions of the Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024 to align them with the latest OECD administrative guidance.
International taxation – global and domestic minimum tax – amending legislation
In 2024, the Australian Government introduced a 15% minimum tax for large companies. The laws are based on rules agreed with the OECD Inclusive Framework. The OECD rules make sure large companies pay at least 15% tax. Minor changes are needed to the law to ensure it is consistent with the OECD rules. The changes are based on OECD guidance on the rules.
The consultation covers:
- An equity investment inclusion election
- Rules on qualified flow-through tax benefits
- An election for regulated mutual insurance companies
- Rules on securitisation entities.
The Rules were substantively enacted at the end of 2024 to implement the domestic framework for a multinational top-up tax, by providing the computations of top-up tax as detailed under the OECD GloBE Model Rules (as modified by the Commentary, Agreed Administrative Guidance and Safe Harbours Rules) (GloBE Rules).
The Amending Rules aim to ensure that administrative guidance issued by the OECD is appropriately incorporated. The Rules must reflect OECD-approved documents so that Australia’s implementation of the GloBE Rules achieves qualified status, which can only be achieved if the Rules are implemented in a manner consistent with the GloBE Rules.
The consultation closes on 21 November 2025.
