Policy updates

Status requires verification

Global Minimum Tax and Domestic Minimum Tax rules for Multinational Enterprises

Australia has implemented OECD’s GloBE rules including Income Inclusion Rule, Undertaxed Profits Rule, and a Domestic Minimum Tax effective from 1 January 2024 (for certain rules) and 1 January 2025 for others. Multinational enterprise groups with foreign operations and relevant thresholds are subject to these rules, affecting debt deductions, tax filings, reporting, and potential top-up taxes. Practical compliance guidelines and administrative systems (GIR, domestic forms) are being developed and consultations held.

Editorial impact label: High

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Jan 1, 2024

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Open cited source

Status requires verification

Global Anti-Base Erosion (GloBE) and Domestic Minimum Tax rules

Australia has implemented key aspects of the OECD/G20 Two-Pillar Solution: a global minimum tax rate of 15% for multinational enterprise groups under an Income Inclusion Rule (IIR) starting 1 January 2024, an Undertaxed Profits Rule (UTPR) from 1 January 2025, and a domestic minimum tax regime. These require MNEs operating in Australia to lodge new returns, provide data via GloBE Information Returns by 30 June 2026, and ensure compliance to avoid penalties. Transitional relief is expected during the early phases.

Editorial impact label: High

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Jan 1, 2024

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Open cited source

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Global Minimum Tax regime implemented (IIR, UTPR, QDMTT)

Korea’s GloBE-based Global Minimum Tax rules under the International Tax Adjustment Act: Income Inclusion Rule effective from January 1, 2024; Undertaxed Payments Rule from January 1, 2025; Qualified Domestic Minimum Top-up Tax from January 1, 2026. Multinational groups with large revenues affected. Proposed 2026 revisions include aligning CFC rules and allowing foreign tax credits for QDMTT.

Editorial impact label: High

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Jan 1, 2024

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Open cited source

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Global and Domestic Minimum Tax (Pillar Two) implementation

Australia has enacted legislation implementing the OECD Global Anti-Base Erosion (GloBE) and Domestic Minimum Tax measures. These impose a 15% global minimum tax and a domestic minimum tax on large multinational enterprise (MNE) groups (annual global revenue ≥ EUR 750 million). The Income Inclusion Rule applies from 1 January 2024, the Undertaxed Profits Rule from 1 January 2025. Australian MNEs must lodge Combined Global and Domestic Minimum Tax Returns, report group entities, pay top-up tax where applicable, and comply with associated record-keeping and API reporting obligations.

Editorial impact label: High

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Jan 1, 2024

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Open cited source

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Global and Domestic Minimum Tax (Australian Pillar Two) API Lodgment Product

Australia has implemented the OECD GloBE rules and corresponding Domestic Minimum Tax through legislation. As of 2026, large multinational enterprise groups in Australia now have obligations to file combined global and domestic minimum tax returns (CGDMTR) for income inclusion rule and undertaxed profits rule. An API product is now active (_Global and Domestic Minimum Tax Return API, Group Entity API, Payment Reference Number API_) to allow lodging entities (or their authorised agents) to submit original or amended returns under this regime. ([apiportal.ato.gov.au](https://apiportal.ato.gov.au/api-products/global-and-domestic-minimum-tax?utm_source=openai))

Editorial impact label: High

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Effective

Jan 1, 2024

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Open cited source

Status requires verification

Global Anti-Base Erosion (GloBE) & Domestic Minimum Tax laws

Australia passed the Taxation (Multinational—Global and Domestic Minimum Tax) Act 2024 and related Acts, along with subordinate legislation Rules 2024. These establish a **15 % global minimum tax** for large multinational enterprise groups with annual global revenue ≥ EUR 750 million, applying from fiscal years starting 1 January 2024 (for Income Inclusion Rule and Domestic Minimum Tax) and 1 January 2025 (for Undertaxed Profits Rule). It strengthens tax integrity by ensuring large MNEs pay a floor tax regardless of jurisdictional tax rates.

Editorial impact label: High

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Jan 1, 2024

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Open cited source

Proposed

Spring Economic Update 2026: Making the Employee Ownership Trust Tax Exemption Permanent

Introduces making permanent the temporary $10 million capital gains tax exemption for qualifying sales of businesses to Employee Ownership Trusts or worker cooperative corporations. Previously scheduled to expire after 2026, this change allows eligible business owners and employees to benefit indefinitely under this regime, helping succession planning and employee ownership.

Editorial impact label: High

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Jan 1, 2024

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Open cited source

Status requires verification

Global and Domestic Minimum Tax Return API changes & obligations

Australia’s implementation of the OECD GloBE rules and Domestic Minimum Tax requires in-scope multinational enterprise groups to lodge combined global and domestic minimum tax returns (CGDMTR), including income inclusion, undertaxed profits, and domestic minimum tax obligations. ATO released updated API specifications (schema, field names) in May 2026 to support these filings.

Editorial impact label: High

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Jan 1, 2024

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Open cited source

Proposed

Employee Ownership Trust Tax Exemption made permanent (proposed)

The temporary Employee Ownership Trust capital gains tax exemption—allowing individuals to shelter up to $10 million in capital gains on qualifying business transfers to an EOT or worker cooperative—was proposed to be made permanent in the Spring Economic Update 2026. Previously, the exemption applies only to qualifying dispositions after 2023 and up to the end of 2026. Implications include greater certainty for business exit and succession planning.

Editorial impact label: High

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Effective

Jan 1, 2024

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Open cited source

Status requires verification

Taxation (Multinational—Global and Domestic Minimum Tax) Act 2024

Australia has enacted laws implementing Australia’s Pillar Two framework, including a 15% global minimum tax for large multinational enterprises (MNEs) with global revenue of EUR 750 million or more. The Income Inclusion Rule applies from fiscal years starting 1 January 2024; the Undertaxed Profits Rule from 1 January 2025. The Domestic Minimum Tax also applies from 1 January 2024. These changes require in-scope MNEs to report via the Global Anti-Base Erosion Information Return (GIR) and comply with Australian-specific interpretations, penalties, and administrative obligations.

Editorial impact label: High

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Effective

Jan 1, 2024

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Open cited source

Proposed

Employee Ownership Trust Tax Exemption to be Made Permanent

Under Spring Economic Update 2026, the current temporary \$10 million capital gains exemption for individuals selling their business to an employee ownership trust or worker cooperative (qualifying dispositions after 2023 through end of 2026) will be made permanent. Allows individuals (other than trusts) to exclude up to \$10 million of capital gains upon qualifying sales, subject to conditions. Businesses considering succession or ownership transition via EOTs or co-ops will now have certainty future transactions will enjoy the exemption.

Editorial impact label: Medium

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Jan 1, 2024

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Open cited source

Proposed

Making the Employee Ownership Trust Tax Exemption permanent (proposed)

In the Spring Economic Update 2026, the government proposed making permanent the temporary $10 million capital gains tax exemption for dispositions of shares to an Employee Ownership Trust or worker cooperative, which currently applies for the 2024-2026 tax years. If enacted, this will provide permanent tax-efficient business succession tools for owners wishing to sell to employee ownership vehicles. It remains a proposal and is not yet law as of publication.

Editorial impact label: High

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Jan 1, 2024

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Open cited source

Status requires verification

Global and domestic minimum tax (Pillar Two) implemented in Australia

Australia has enacted legislation (Taxation (Multinational—Global and Domestic Minimum Tax) Act 2024 and related rules) implementing OECD Pillar Two: a **15% global minimum tax rate** for in-scope multinational enterprise (MNE) groups with the Income Inclusion Rule applying from fiscal years starting on or after 1 January 2024, and the Undertaxed Profits Rule from 1 January 2025. The domestic minimum tax also applies from 1 January 2024. It aims to ensure large multinationals pay a minimum effective tax rate in Australia and abroad, reducing base erosion and profit shifting risks.

Editorial impact label: High

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Jan 1, 2024

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Open cited source

Status requires verification

ATO guidance on Australia’s Pillar Two global and domestic minimum tax rules (Amending Rules in effect)

The Amending Rules under Australia’s Pillar Two regime clarify aspects such as interaction with tax consolidation, treatment of deferred tax assets, the allocation of GloBE income and adjusted covered taxes; these rules are retrospective from 1 January 2024. The ATO has published updated guidance, and lodgment deadlines for certain returns have been deferred to 30 July 2026.

Editorial impact label: Medium

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Jan 1, 2024

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Open cited source

Status requires verification

Revenue Procedure 2025-17 adds Ukraine, Iraq, Haiti, and Bangladesh as waiver countries under section 911 for 2024

Under Rev. Proc. 2025-17, the minimum time requirements for the bona fide residence or physical presence tests are waived for U.S. citizens or residents who were forced to leave Ukraine, Iraq, Haiti, or Bangladesh during tax year 2024 due to war, civil unrest, or similar adverse conditions. This allows eligible individuals to still claim the Foreign Earned Income Exclusion when otherwise they might not meet residency/presence thresholds.

Editorial impact label: Medium

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Jan 1, 2024

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Open cited source

Status requires verification

Clean Technology Manufacturing Investment Tax Credit (CTM ITC) Implementation

The Clean Technology Manufacturing Investment Tax Credit, a refundable credit to encourage clean-tech manufacturing, processing, and critical mineral operations in Canada, was enacted by legislation receiving Royal Assent on March 26, 2026. It applies retroactively from January 1, 2024 through December 31, 2034. Eligible Canadian corporations may include qualifying ITC assets in their returns and potentially obtain refunds even with low income or losses.

Editorial impact label: High

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Effective

Jan 1, 2024

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Open cited source

Status requires verification

Australia’s global minimum tax and domestic minimum tax now law (Pillar Two)

The Taxation (Multinational—Global and Domestic Minimum Tax) Act 2024 and supporting rules implement the OECD’s Pillar Two solution: 15% global minimum tax for large multinationals, including Income Inclusion Rule from 1 January 2024, Undertaxed Profits Rule from 1 January 2025, and a Domestic Minimum Tax. Includes safe harbours, new integrity provisions for FITO, and embedded obligations across entities. ([ato.gov.au](https://www.ato.gov.au/about-ato/new-legislation/in-detail/international/implementation-of-a-global-minimum-tax-and-a-domestic-minimum-tax?utm_source=openai))

Editorial impact label: High

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Effective

Jan 1, 2024

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Open cited source

Cyprus

Status requires verification

Pillar 2 Global Minimum Tax Directive: New FAQ confirms qualified status of Cyprus’s Income Inclusion Rule

On 29 May 2026, the European Commission published a FAQ clarifying that Cyprus’s IIR should be treated by all EU Member States as being qualified under the EU Pillar Two Directive for fiscal years beginning on or after 31 December 2023. This ensures mutual recognition, enabling Cyprus to receive top-up tax information returns and exchange data under DAC9 without triggering domestic filings elsewhere. The directive is active and binding, meaning companies must align accordingly.

Editorial impact label: Medium

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Effective

Dec 31, 2023

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Open cited source

Cyprus

Status requires verification

All EU Member States must treat Cyprus as having a qualified Income Inclusion Rule under the Pillar Two Directive

On 29 May 2026, the European Commission issued a FAQ clarifying that although Cyprus’s Income Inclusion Rule (IIR) does not yet appear on the OECD Central Record of qualified legislation, **EU law requires all Member States to treat it as qualified** for fiscal years starting on or after 31 December 2023. This ensures that Pillar Two obligations are uniformly recognised across the Union, avoiding gaps for multinationals with Cypriot entities.

Editorial impact label: Medium

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Dec 31, 2023

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Open cited source

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What’s new for corporations: Global minimum tax

Introduction of Canada’s Global Minimum Tax for large multinational enterprises (MNEs) with worldwide revenues over €750 million. Corporations with fiscal years starting on or after December 31, 2023 must comply with new rules including global minimum effective tax rate of 15%, separate filing obligations under the Global Minimum Tax Act, and potential penalties for non-compliance.

Editorial impact label: High

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Dec 31, 2023

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Open cited source