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How Australia’s Pillar Two Rules Will Reshape Global Minimum Tax Compliance for Multinationals

Australia’s implementation of OECD Pillar Two rules brings significant changes: global and domestic minimum taxes now apply, compliance deadlines are set, and transitional reliefs are available under new ATO guidance.

By NomadicTax Research Team · 5-8 min read

What Are Australia’s Pillar Two Rules?

Australia has officially legislated key aspects of the OECD/G20 two-pillar global tax reform—known as Pillar Two. Under the legislation:

  • The Income Inclusion Rule (IIR) and Domestic Minimum Tax (DMT) apply for fiscal years starting on or after 1 January 2024. (ato.gov.au)
  • The Undertaxed Profits Rule (UTPR) applies beginning 1 January 2025. (ato.gov.au)

These measures ensure large multinational enterprise (MNE) groups with global revenue of EUR 750 million or more pay at least 15% tax in each jurisdiction where they operate. (ato.gov.au)

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