Global Daily Tax News, Australia Provides Update On Pillar Two Engagement And Guidance, (Oct 6, 2025)

The Australian Taxation Office has confirmed it plans to offer another event in November 2025 to support multinational enterprises to comply with the country's Pillar Two tax rules.

The agency held a first open information session in August 2025, to discuss with stakeholders the implementation of the global minimum tax framework, including Australia's domestic minimum top-up tax. The ATO said the sessions are important not only to support taxpayers and agents with adapting to the changes but also to steer the ATO's efforts to develop guidance and offer support.

The August session covered:

• an overview of the Pillar Two rules;

• Australia's legislation and guidance;

• key taxpayer obligations; and

• how the ATO is supporting the market and next steps.

The ATO has confirmed the release of guidance on many of the topics that attendees raised during the session and committed to continue to update its website to expand the agency's guidance.

For instance, on the impact of the Pillar Two rules on permanent establishments, it pointed stakeholders to guidance on its website on when and how the Pillar Two rules apply.

Further, it noted that one of the main topics that attendees raised was lodgment obligations. It said that its webpage includes guidance on lodging, paying, and other obligations for Pillar Two, which covers queries on:

• who can lodge on behalf of a permanent establishment;

• lodging the GIR, including if the constituent entity applies for safe harbor;

• lodging information for constituent entities that meet the transitional safe harbor;

• lodging requirements for Australian entities where there are multiple subsidiaries in Australia for the one MNE group; and

• nominating a designated filing entity included in the foreign lodgment notification.

The ATO further said taxpayers should review draft Legislative Instrument 2025/D17, which sets out the circumstances where a group entity of an in-scope multinational enterprise (MNE) does not need to lodge the Australian IIR/UTPR Tax Return and the DMT Tax Return for a fiscal year.

The ATO also confirmed that it is expected that Australia will sign the GIR Multilateral Competent Authority Agreement. However, it said, "this is a matter for Treasury not the ATO." It said: "We'll continue to update our web content about the GIR in the coming months."

On the next session, the ATO concluded: "We'll be holding another Pillar Two open information session in November. We'll share more details, including how to register, closer to the date."

"We will regularly update our website with expanded guidance, including information on safe harbours and consolidations. We are expecting to publish updates in the next few weeks," the ATO concluded.