ato logo
Search Suggestion:

Pillar Two Global Domestic Minimum Tax Working Group key messages 30 August 2024

Key topics discussed at the Pillar Two Global and Domestic Minimum Tax meeting 30 August 2024.

Last updated 20 November 2024

Group purpose

The Pillar Two Global and Domestic Minimum special purpose working group was established to discuss and seek feedback on the administrative aspects of the implementation of the Pillar Two measure.

Pillar Two forms

The ATO project team presented and were provided feedback on forms currently under development, including the:

  • GloBE Information Return (GIR)
  • Foreign lodgment notification
  • Australian IIR / UTPR Tax Return (AIUTR)
  • Domestic Minimum Tax Return (DMTR).

The focus was on the data points, which was discussed in detail with the group. The ATO took a generally minimalistic approach to their form design given many of the relevant disclosures will be included in the standardised GIR developed by the Organisation for Economic Co-operation and Development (OECD).

The OECD is in the process of developing additional guidance to ensure a consistent and standardised approach to capturing, filing and exchanging GIR information.

The draft forms contain placeholders for certain sections still being progressed by the ATO and the OECD. This includes work on incorporating declarations that may be required as result of the Global and Domestic Minimum Tax Act (currently before Parliament) and data points in respect of identifying unincorporated entities.

Member comments

Members raised the following points regarding the Pillar Two lodgment forms:

  • How do the jurisdictions of the relevant entities affect the form-filling requirements.
  • Practical considerations regarding where the GIR is lodged with a foreign government agency in relation to Australia's reporting requirements and administrative considerations.
  • Including a list of countries Australia has appropriate exchange of information agreements about the GIR exchange mechanism.
  • Instances that require specific forms be completed where the liability to pay top-up tax is nil.
  • The use of language in the draft forms and maintaining uniformity with the OECD's standard approach.

The comments and suggestions provided by the working group members were considered, with updates being made to the lodgment forms.

QC103389