Compliance
Global Minimum Tax (Pillar Two) compliance & what multinational enterprises must do by 30 June 2026
Australia’s Pillar Two rules require MNEs to file multiple returns—and the ATO has consolidated some into a Combined Global & Domestic Minimum Tax Return—but lodgement and payment due dates loom.
By NomadicTax Research Team • 6 min read • May 1, 2026
## What are Pillar Two and associated obligations?
Pillar Two refers to Australia’s implementation of the **Global & Domestic Minimum Tax (GloBE and DMT)** rules. Multinational enterprise (MNE) groups that meet thresholds must lodge:
- the **Global Anti-Base Erosion Model (GIR) Information Return**,
- the **Australian Income Inclusion/Undertaxed Profits Return (AIUTR)**,
- the **Domestic Minimum Tax Return (DMTR)**,
- and the **Foreign Lodgement Notification (FLN)**. ([bdo.com.au](https://www.bdo.com.au/en-au/insights/tax/articles/ato-releases-an-update-on-the-new-pillar-two-compliance-guidelines?utm_source=openai))
In **March 2026**, the ATO released a **final combined form** called the **Combined Global and Domestic Minimum Tax Return (CGDMTR)** which bundles together FLN, AIUTR and DMTR. GIR remains a separate lodgement. ([bdo.com.au](https://www.bdo.com.au/en-au/insights/tax/articles/ato-releases-an-update-on-the-new-pillar-two-compliance-guidelines?utm_source=openai))
## Deadlines & who is affected
- For MNE groups with **fiscal year ending 31 December 2024**, their Pillar Two returns are due by **30 June 2026**. ([bdo.com.au](https://www.bdo.com.au/en-au/insights/tax/articles/ato-releases-an-update-on-the-new-pillar-two-compliance-guidelines?utm_source=openai))
- Some entities may appoint a **Designated Local Entity (DLE)** to lodge CGDMTR on their behalf if they meet eligibility criteria—provided they aren't excluded from Pillar Two rules. ([bdo.com.au](https://www.bdo.com.au/en-au/insights/tax/articles/ato-releases-an-update-on-the-new-pillar-two-compliance-guidelines?utm_source=openai))
- Automatic **30-day lodgement deferrals** have been announced for AIUTR and DMTR for first-year filings (fiscal years starting in 2024), but **payment dates are not deferred** automatically. ([pwc.com.au](https://www.pwc.com.au/tax/tax-alerts/australias-pillar-two-lodgement-obligations-and-exemptions.html?utm_source=openai))
## What changes this brings for cross-border enterprises
- Entities must **review their group structure** to identify which parts are in scope under the rules and who will lodge clearly.
- **System changes and data gathering** are needed to produce accurate GIR reports (financial statements, tax incentives, jurisdiction computations). ([pwc.com.au](https://www.pwc.com.au/tax/tax-alerts/australias-pillar-two-lodgement-obligations-and-exemptions.html?utm_source=openai))
- Non-compliance carries risk: penalties may arise for failing to lodge, late payments or incorrect information. Some relief in early years under transitional or “soft landing” arrangements; expect strict future enforcement. ([pwc.com.au](https://www.pwc.com.au/tax/tax-alerts/australias-pillar-two-lodgement-obligations-and-exemptions.html?utm_source=openai))
## Practical steps for compliance
1. **Identify whether your group is in scope**—check revenue, size, jurisdictions involved.
2. **Determine whether a DLE is feasible or helpful**—centralizing lodgement under one entity might reduce burden.
3. **Gather necessary inputs**: financial results, tax offsets, jurisdictional data for GIR; for DMTR/AIUTR, assess undertaxed profits etc.
4. **Check software systems or work with advisors**—many may need to upgrade or tweak to handle complex reporting.
5. **Mind the payment timelines**—even with lodgement deferrals, any tax owing is due on original dates unless separately deferred. Don't wait until it's too late.
## Example scenario
> GlobalCo Pty Ltd, part of a multinational group with a 31 December 2024 year-end, must file its GIR by 30 June 2026. It has income inclusion and domestic minimum tax obligations, so will lodge CGDMTR combining those returns. Because this is its first year, GlobalCo can use the automatic 30-day lodgement deferral for AIUTR/DMTR but still needs payment due on time. Systems upgrades ensure accurate tracking of foreign tax credits and jurisdictional income.
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**Take-away**: For MNEs, Pillar Two is no longer negotiation—it’s a current obligation. Ensure robust reporting, timely lodgement, and get clear on your obligations well before 30 June 2026.