Entity Setup
Australia’s Global and Domestic Minimum Tax (GloBE Rules): What Multinational Groups Must Know
Australia has implemented the OECD’s GloBE rules with key dates already past – ensuring multinational groups understand their obligations and how to use the ATO’s new CGDMTR API is critical.
By NomadicTax Research Team • 5-8 min read • April 2, 2026
## Introduction
Australia has legislated the **Global Anti-Base Erosion (GloBE) rules**, introducing both a **global and domestic minimum tax** to ensure multinational enterprises (MNEs) cannot shift profits to low-tax jurisdictions without being taxed. The ATO’s **Combined Global and Domestic Minimum Tax Return (CGDMTR) API** is now available for reporting. ([softwaredevelopers.ato.gov.au](https://softwaredevelopers.ato.gov.au/Pillar2?utm_source=openai))
## Key Dates & Rules
- From **1 January 2024**, the Income Inclusion Rule (IIR) applies to relevant income years; the Undertaxed Profits Rule (UTPR) from **1 January 2025**. ([softwaredevelopers.ato.gov.au](https://softwaredevelopers.ato.gov.au/Pillar2?utm_source=openai))
- The **15% Domestic Minimum Tax (DMT)** also applies for income years starting **1 January 2024**. ([softwaredevelopers.ato.gov.au](https://softwaredevelopers.ato.gov.au/Pillar2?utm_source=openai))
- MNE groups are expected to lodge foreign lodgment notifications when required. ([apiportal.ato.gov.au](https://apiportal.ato.gov.au/api-products/global-and-domestic-minimum-tax?utm_source=openai))
## Reporting via ATO API
The **CGDMTR API** allows MNEs and their tax agents to lodge:
- **Foreign lodgment notification**
- **Australian IIR/UTPR top-up tax liabilities**
- **Domestic Minimum Tax (DMT) liabilities**
The API supports **original and amendment lodgments**, handles up to **300 group entities**, and requires valid identifiers (TFN, ABN, ARN, TIN) for both lodging entities and group entities. ([apiportal.ato.gov.au](https://apiportal.ato.gov.au/api-products/global-and-domestic-minimum-tax?utm_source=openai))
## Practical Implications & Compliance Tips
- **Assess whether you’re in scope**: MNEs with global turnover above the relevant threshold must comply; lower-turnover groups may be exempt but still subject to domestic minimum tax rules.
- **Ensure accurate data**: Identify all group entities, ensure up-to-date identifiers, addresses, and statutory data (for both Australian and foreign entities).
- **Use the API effectively**: Set up system workflows for both original and amendments; track transaction ID requirements for group entity returns. ([apiportal.ato.gov.au](https://apiportal.ato.gov.au/api-products/global-and-domestic-minimum-tax?utm_source=openai))
- **Monitor tax liabilities**: IIR and UTPR rules can lead to top-up taxes based on profits taxed below 15% elsewhere. Ensure transfer pricing and valuation align with OECD and ATO expectations.
## Example
Suppose an Australian company is part of a group with overseas subsidiaries. For the year ending 31 December 2024, those subsidiaries had profits taxed at 10% in their jurisdictions. Under the IIR, Australia may impose a top-up to reach the 15% minimum. The Australian group uses the CGDMTR API to lodge:
- Foreign lodgment notification (if one of the entities is the Designated Filing Entity)
- A group entity tax return for the subsidiaries at 10% rate indicating IIR top-up tax
- Payment Reference Numbers to settle liabilities
## Strategic Tax Planning Insights
- Evaluate off-shore tax rates now that you know the 15% threshold. Investing in jurisdictions with compliant tax rates may reduce exposure.
- Review transfer pricing policies, holding structures, and financing arrangements.
- Use the API’s amendment functions to correct earlier filings where data was incomplete or incorrect.
## Conclusion
The GloBE rules are no longer optional for in-scope multinational groups operating in Australia. With key deadlines in the past and the CGDMTR API live, action is required now to ensure compliance, optimize outcomes, and avoid penalties.