Entity Setup
Global Profit, Domestic Tax: Navigating Australia’s Pillar Two Rules for Multinationals
Australia has adopted OECD Pillar Two rules imposing a 15% global minimum and domestic minimum tax; multinationals must comply with new lodgment obligations starting for years from 2024–25. Here’s what entity groups need to know.
By NomadicTax Research Team • 5-8 min read • March 1, 2026
## What Are Pillar Two Rules?
Pillar Two refers to global tax reforms developed by the OECD to ensure large multinational enterprise (MNE) groups pay a **minimum rate of 15% tax** in each country where they operate. Australia has implemented two legs of these rules:
- The **Income Inclusion Rule (IIR)** from 1 January 2024([corrs.com.au](https://www.corrs.com.au/insights/federal-budget-2025-re-announcements-deferrals-and-ato-funding?utm_source=openai))
- The **Undertaxed Profits Rule (UTPR)** effective from 1 January 2025([softwaredevelopers.ato.gov.au](https://softwaredevelopers.ato.gov.au/Pillar2?utm_source=openai))
- The **Domestic Minimum Tax (DMT)** also applies from 1 January 2024([softwaredevelopers.ato.gov.au](https://softwaredevelopers.ato.gov.au/Pillar2?utm_source=openai))
## Who is Affected?
- **Large MNE groups** with annual global revenue that bring them into scope under ATO rules.
- **Designated Local Entities (DLEs)** will generally lodge the Combined Global and Domestic Minimum Tax Return (CGDMTR) covering IIR, UTPR, and DMT obligations. ([apiportal.ato.gov.au](https://apiportal.ato.gov.au/api-products/global-and-domestic-minimum-tax?utm_source=openai))
## Key Lodgment Requirements
| Obligation | Deadline / Effective From | What Must Be Lodged |
|------------|----------------------------|----------------------|
| CGDMTR via API | Original and amendments permitted; test scenarios available ([apiportal.ato.gov.au](https://apiportal.ato.gov.au/api-products/global-and-domestic-minimum-tax/test-scenarios?utm_source=openai)) | Includes Foreign Lodgment Notification, Australian IIR/UTPR return, Australian DMT return |
| Information Return (GIR) | First lodgment due by **30 June 2026** for income years ending before that date ([pwc.com.au](https://www.pwc.com.au/tax/tax-alerts/australias-pillar-two-lodgement-obligations-and-exemptions.html?utm_source=openai)) | Reporting group entities, calculating top-up tax and determining obligations |
## Practical Steps for Entities & Tax Practitioners
- **Assess group’s global turnover**: Are you in scope? Determine if your revenue is above the thresholds defined in the ATO guidance.
- **Review group entity structure**: Which entities are “in scope” and who is the DLE? Ensure all group entities are identified.
- **Establish data systems**: Collect necessary financial and jurisdictional data to compute IIR, UTPR, and DMT. This often involves system upgrades.
- **Liaise with software developers or DSPs**: Use the ATO’s API portal for lodging returns. Testing scenarios are available for responses and PRNs (payment reference numbers). ([apiportal.ato.gov.au](https://apiportal.ato.gov.au/api-products/global-and-domestic-minimum-tax/test-scenarios?utm_source=openai))
## Example
Acme Global Ltd operates in Australia, UK, and Singapore. It's headquartered in Singapore but has an Australian branch. It has global revenue exceeding EUR 750 million.
- Acme must now check whether the IIR applies (yes, from 1 Jan 2024), and whether any UTPR is triggered (from 1 Jan 2025).
- If those triggers apply, Acme or its DLE must lodge the CGDMTR via the ATO-approved APIs.
- Acme also must compute if Australian top-up tax or domestic minimum tax (DMT) is payable, depending on whether income was taxed below 15% abroad. Any liability must be paid following lodgment.
## Implications & Risks
- **Top-up tax payable**: If income in any jurisdiction is taxed below 15%, the ATO may impose additional tax under IIR or DMT rules.
- **Increased compliance burden**: More tracking, reporting, and potential audits—errors or omissions could lead to penalties.
- **Transparency into foreign earnings**: Foreign earnings and jurisdictions must be disclosed—lack of disclosure could cause regulatory or reputational risk.
## Timeline To Know
- **Years starting 1 Jan 2024**: IIR and DMT obligations apply. Keep detailed records of foreign income and taxes paid.
- **Years starting 1 Jan 2025**: UTPR becomes enforceable. All affected entities should prepare.
- **30 June 2026**: Deadline for many groups to lodge their first minimum tax return(s). ([pwc.com.au](https://www.pwc.com.au/tax/tax-alerts/australias-pillar-two-lodgement-obligations-and-exemptions.html?utm_source=openai))
## Summary
Australia’s adoption of Pillar Two rules marks a pivotal shift in multinational taxation—mandating minimum tax levels and increasing transparency. Entities in scope must act quickly to ensure accurate reporting, compliant tax filings, and avoid inadvertent exposure to penalties or unexpected liabilities.