Global Daily Tax News, Australia Consults On Minimum Tax Law Amendments, (Oct 29, 2025)

The Australian Treasury on October 27, 2025, launched a consultation on proposed changes to the nation's Pillar Two minimum top-up tax regime.

The changes are included in the draft Taxation (Multinational and Domestic Minimum Tax) Amendment (2025 Measures No.1) Rules 2025, which will amend the Taxation (Multinational and Domestic Minimum Tax) Act 2024. The Treasury has also released an explanatory memorandum on the changes.

The Rules are intended to ensure that Australia's regime remains in step with additions to the OECD's Pillar Two global minimum tax framework, including new guidance agreed by the Inclusive Framework.

The Treasury said the main changes proposed would:

• clarify the limited circumstances where Securitisation Entities would be liable to pay Undertaxed Profits Rule (UTPR) top-up tax;

• insert into law an Equity Investment Inclusion Election and specify the related rules on qualified flow-through tax benefits;

• clarify the Investment Entity Transparency Election for Regulated Mutual Insurance Companies; and

• make minor amendments to the Domestic Minimum Tax (DMT) provisions.

Feedback is being sought by November 21, 2025.