Compliance
Navigating Australia’s Global Minimum Tax Rules: What Multinationals Need to Know
Australia’s Pillar Two measures are now law—multinationals with EUR 750 million+ global revenue must adapt to its Global and Domestic Minimum Tax rules from January 2024. Understand obligations, documentation, and compliance strategies.
By NomadicTax Research Team • 6 min read • May 10, 2026
## What are the Global and Domestic Minimum Tax Rules?
Australia implemented the OECD’s *Pillar Two* framework via several pieces of legislation, including the **Taxation (Multinational—Global and Domestic Minimum Tax) Act 2024**, the **Taxation (Multinational—Global and Domestic Minimum Tax) Imposition Act 2024**, and associated rules. These laws impose:
- A **15% global minimum tax** on large multinational enterprise (MNE) groups with annual global revenues of EUR 750 million or more; the **Income Inclusion Rule** applies from fiscal years starting 1 January 2024, and the **Undertaxed Profits Rule** from 1 January 2025.([ato.gov.au](https://www.ato.gov.au/api/public/content/0-19a11d5f-5a98-4cff-ba03-5aea1b50aaf2?utm_source=openai))
- A **15% domestic minimum tax** also applying from 1 January 2024 for those in-scope entities.([ato.gov.au](https://www.ato.gov.au/api/public/content/0-19a11d5f-5a98-4cff-ba03-5aea1b50aaf2?utm_source=openai))
## Key Obligations for Multinationals
### Whose revenues count?
- Your group must reach the EUR 750 million global revenue threshold in the prior financial year. This includes all group operations worldwide. If you meet that, the Pillar Two rules kick in.
### Reporting Requirements
- Entities must submit a **Global Anti-Base Erosion Information Return (GIR)**, with detailed financial and tax data. Stakeholders have raised concerns about the complexity of data required and system upgrades needed.([ato.gov.au](https://www.ato.gov.au/businesses-and-organisations/international-tax-for-business/in-detail/multinationals/global-and-domestic-minimum-tax/pillar-two-consultation?utm_source=openai))
- Be aware of **administrative penalties** that apply for misreporting, domestic adjustments, and late lodgments—for both affiliate undertakings and group income.([ato.gov.au](https://www.ato.gov.au/businesses-and-organisations/international-tax-for-business/in-detail/multinationals/global-and-domestic-minimum-tax/pillar-two-consultation?utm_source=openai))
## Compliance Strategies & Planning
- **Conduct an internal readiness review** quickly. Map how your group currently does tax and accounting to the new GIR requirements—identify gaps in data sources, systems, and people.
- If you operate in multiple jurisdictions with foreign minimum tax measures, examine **how rules overlap** and whether double credit mechanisms or carve-outs apply.
- Use safe harbours wherever available to limit exposure. Australia’s consultations suggest reliance on safe harbours is expected.([ato.gov.au](https://www.ato.gov.au/businesses-and-organisations/international-tax-for-business/in-detail/multinationals/global-and-domestic-minimum-tax/pillar-two-consultation?utm_source=openai))
- Ensure your digital service providers and tax software support the GIR and other deliverables by reviewing the ATO’s timing and technical note updates. Be ready for potentially significant updates to workflows and reporting tools.
## Real-World Example
**Case: ApexTech Global** operates in Australia and globally, exceeding the EUR 750 million threshold for FY2023 and is in scope under the Income Inclusion Rule.
- In late 2024, ApexTech identified missing supporting balances for certain foreign tax credits that will now need to be included in the GIR for FY2024.
- They engaged with their financial systems vendor to ensure that GIR-relevant data flows are being captured and automated to minimize manual intervention.
- ApexTech also reviewed loans and royalty payments to assess whether any are mischaracterised under anti-base erosion provisions, preparing robust documentation for defense.
## Takeaways
- If you run a large, cross-border business, the **Global Minimum Tax is now law in Australia**—you must act.
- Start collecting data, engage your people, evaluate your systems.
- Missing or late GIR or underestimating domestic adjustments can lead to penalties or unexpected tax exposure.
Stay ahead with early compliance—preparation now avoids last-minute scramble and potential financial risk.