Pillar Two in Australia
Australia has implemented OECD Pillar Two through Taxation (Multinational – Global and Domestic Minimum Tax) Act 2024 (Assessment Act). Each applies to fiscal years beginning on or after the respective date: the IIR from 2024-01-01, the QDMTT from 2024-01-01, the UTPR from 2025-01-01.
Implementation Timeline
Each rule applies to fiscal years beginning on or after the date shown.
Quick reference
| Rule | Effective date | Status |
|---|---|---|
| IIR — Income Inclusion Rule | Fiscal years beginning on or after 2024-01-01 | In force OECD qualified |
| UTPR — Undertaxed Profits Rule | Fiscal years beginning on or after 2025-01-01 | In force OECD review pending |
| QDMTT — Qualified Domestic Minimum Top-up Tax | Fiscal years beginning on or after 2024-01-01 | In force OECD qualified |
| QDMTT Safe Harbour | Available alongside the QDMTT | Case-by-case |
Implementing legislation
- Taxation (Multinational – Global and Domestic Minimum Tax) Act 2024 (Assessment Act) — IIR·UTPR·QDMTT 본 규정
- Taxation (Multinational – Global and Domestic Minimum Tax) Imposition Act 2024 — additional세액 부과 근거
- Treasury Laws Amendment (Multinational – Global and Domestic Minimum Tax) Act 2024 — 관련 법률 amendment (in force and 기술적 사항)
- UTPR — 1년 지연되어 2025-01-01 in force from fiscal years beginning on or after the date shown
Practical implications
MNE groups parented in Australia are subject to the IIR for fiscal years beginning on or after 2024-01-01. Where a subsidiary's jurisdictional effective tax rate (ETR) falls below 15%, top-up tax is computed and paid in Australia (as the jurisdiction of the parent entities), and the group must also file the GloBE Information Return (GIR).
MNE groups with constituent entities in Australia are subject to Australia's QDMTT for fiscal years beginning on or after 2024-01-01. Where the conditions of the QDMTT Safe Harbour are met, the IIR/UTPR computation at the parent jurisdictions may be exempted, reducing the burden of dual computation.
Recent legislative developments
- 2024-12: Pillar Two 본 법률 일괄 통과 — Assessment Act + Imposition Act + 관련 amendment (2024-01-01 소급 in force)
Related terms
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- OECD Inclusive Framework — Updated Central Record for Purposes of the Global Minimum Tax, approved 2026-05-11 (current as at 2026-05-01). OECD Global Minimum Tax
- Australian Taxation Office (ATO) — Pillar Two guidance and 가이드. www.ato.gov.au
- Federal Register of Legislation — Australia 연방 법령 — Taxation (Multinational – Global and Domestic Minimum Tax) Act 2024. www.legislation.gov.au
Disclaimer
This page is reference information prepared as of 2026-05-28 by synthesising the primary sources listed above, and is not legal or tax advice. Before applying any of this material in practice, please:
- Verify the latest legislation, administrative guidance, and tax authority notices
- Obtain review by a qualified Pillar Two specialist
- Reassess applicability against the specific facts and circumstances of the group
Translation note. The authoritative version of this page is the Korean original (국가별 현황 › 호주). This English version is provided for accessibility and may not capture every nuance of the original sources. Where precision matters, please refer to the Korean original or to the source legislation in its original language.