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Australian 15% global and domestic minimum taxes law introduced into Parliament


At a glance

  • Legislation introduced to implement:
    • An Income Inclusion Rule (IIR) applying to years starting from 1 January 2024
    • An Undertaxed Profits Rule (UTPR) applying to years starting from 1 January 2025
    • A domestic minimum tax (DMT) applying to years starting from 1 January 2024.
  • In-scope MNE Groups will be required to lodge at least three new returns in an approved form to the ATO:
    • A GloBE Information Return (GIR)
    • An Australian IIR/UTPR Tax Return
    • DMT Return(s).
  • How EY can help.

On 4 July 2024, the Australian Government introduced legislation into Parliament, to implement Australia’s adoption of the OECD/G20 Pillar Two solution, including a 15 per cent global minimum tax and domestic minimum tax (DMT) following public consultation of exposure drafts (EDs) in March 2024.

This Tax Alert outlines the key aspects of the primary legislation, the major changes from the EDs released in March 2024 and the implications of those changes.

The introduction of the Bills to Parliament represents a significant step forward in Australia’s implementation of Pillar Two. All three Bills have been referred to the Senate Economics Legislation Committee for inquiry with a report due by 14 August 2024. Following this, the Bills should advance quickly through the remaining legislative process and be enacted.

Australian-based and global groups with a presence in Australia should continue to progress their Pillar Two impact assessments, modelling and BEPS software implementation projects, as well as assess the impact of this development on their June 2024 financial statements.

Download this tax alert