The ATO releases an update on the new Pillar Two compliance guidelines

There are four lodgement requirements as part of Australia’s global and domestic minimum tax rules being;

1. The Global Anti-Base Erosion Model (GloBE) Information Return (GIR)
2. The Foreign Lodgement Notification form
3. The Australian income inclusion rule (IIR)/undertaxed profits rule (UTPR) tax return (AIUTR)
4. The Australian domestic minimum tax (DMT) return (DMTR).

On 12 March 2026, the Australian Taxation Office (ATO) released the final Australian Pillar Two compliance forms, which combines the Foreign Lodgement Notification, AIUTR and DMTR forms into a single form called the Combined Global and Domestic Minimum Tax Return (CGDMTR).

This information is timely, particularly for members of MNE groups with fiscal year ends of 31 December 2024, because their lodgement due dates for their Pillar Two returns is 30 June 2026.

There are two combined compliance forms depending on whether the entity is filing the Pillar Two reporting obligations as;

1. A Designated Local Entity (DLE) on behalf of other Australian entities
2. A stand-alone entity as part of a larger group.

The CGDMTR is available through ATO online services (for agents or for business) and via API-enabled software.

For a DLE lodging on behalf of other group entities, the ATO online services form supports up to 20 entities per lodgement (including the DLE). Otherwise, the CGDMTR will need to be lodged via the API channel which supports up to 300 entities.

It is important to note the GIR is lodged separately from the CGDMTR. The GIR is a global information return used for risk assessment and verification and is shared across multiple jurisdictions. The GIR does not create a top-up tax assessment.

The CGDMTR is Australia-specific and enables domestic assessment and payment processes.

An MNE group may nominate a DLE to lodge the GIR and may also nominate the same DLE to lodge the CGDMTR.

A DLE must be an:

1. Australian GloBE-located group entity
2. Nominated by relevant Australian group entities for the relevant reporting obligations, and
3. Must not be an excluded entity or a permanent establishment.

There is no separate nomination form to appoint a DLE. The ATO currently expects the DLE details identified in the GIR and CGDMTR are supported by internal written records. Groups will need to consider how their Tax Governance Policy and related procedures documents need to be updated to reflect the Australian group’s Pillar Two obligations.

At this stage, the ATO must be contacted to advise of changes to the composition of reporting groups where there are entities leaving/joining groups during the year so the ATO can advise how to lodge to reflect these changes.

The ATO has also issued practical compliance guidelines (PCG 2025/4) that outline their approach to supporting taxpayers with regards to lodgement concessions and support during the transitional period. Importantly, the ATO does not have discretion to grant an extension to lodge the GIR or the Foreign Lodgement notification but may agree to suspend lodgement compliance action for a period.

Practical actions in preparation for the first lodgement date

While the ATO’s March 2026 update focuses on the structure of the new forms and how they are lodged, it also points to several practical actions that in‑scope MNE groups should now be taking to prepare for compliance:

1. Confirm which Pillar Two obligations apply

As a first step, groups should confirm which of the new Pillar Two lodgement obligations apply to their Australian entities. The ATO has made clear that separate obligations exist for the GIR, the foreign lodgement notification, the Australian IIR/UTPR Tax Return (AIUTR) and the Australian Domestic Minimum Tax Return (DMTR), even though some of these are now combined into a single form for lodgement purposes. Importantly, lodgement may still be required even where no top‑up tax is payable.

2. Decide who will lodge on behalf of the group

The ATO guidance contemplates that a DLE may lodge the combined global and domestic minimum tax return (CGDMTR) on behalf of multiple Australian group entities. Groups should therefore determine whether to nominate a DLE and, if so, which entity will perform that role. This decision has downstream implications for how many entities can be included in a single lodgement and which lodgement channel can be used.

3. Ensure access to the correct ATO lodgement channels

The CGDMTR must be lodged electronically. The ATO confirms that lodgement can occur through online services for business, online services for agents, or via API‑enabled software. Groups should ensure that the relevant entity (or its tax agent) has access to the appropriate ATO online services well in advance of the due date. Where an API solution is intended to be used, early engagement with software providers may be required.

4. Manage entity limits and data scope

The ATO has introduced practical limits on the number of entities that can be included in a single CGDMTR lodgement, depending on the channel used.

5. Plan separately for the GloBE Information Return

The ATO reiterates that the GIR is not part of the combined return and must be lodged separately, either in Australia or in a foreign jurisdiction. Where the GIR is lodged offshore, an Australian foreign lodgement notification is still required. Groups should ensure there is clear coordination between the global GIR filing and the Australian Pillar Two lodgements so that notifications are lodged accurately and on time.

6. Maintain records to support lodgement

The ATO’s broader Pillar Two guidance highlights the importance of record‑keeping to support compliance with the global and domestic minimum tax. Groups should ensure that the information used to complete the CGDMTR and any GIR is retained and can be substantiated if required.

How BDO can help

Should you have any questions about this update, please contact your BDO tax adviser for further guidance, or visit our tax services page to see how we can help.