ATO releases further guidance on the new Pillar Two lodgement, payment, and compliance obligations

Australia’s new Pillar Two global minimum tax regime (effective for income years starting on or after 1 January 2024) imposes significant new compliance obligations on large multinational enterprise (MNE) groups. In-scope MNEs (i.e., those with annual consolidated revenue of €750 million or more, in at least two of the last four years) must ensure a 15 per cent minimum effective tax rate in each jurisdiction via ‘top-up’ taxes.  

MNEs are required to lodge new returns and pay any top-up tax to the Australian Taxation Office (ATO) on a strict timeline, even if no additional tax is ultimately due.  

To implement Pillar Two, Australia has introduced four new lodgement requirements (returns/notifications) as part of the compliance regime.

New lodgement requirements 

1. Global Anti-Base Erosion Model (GloBE) Information Return (GIR) 

This is a comprehensive information return detailing the Pillar Two calculations and data for the MNE group. The GIR format is based on the Organisation for Economic Co-operation and Development (OECD) template and is intended to allow tax authorities to assess an MNE’s compliance with the GloBE rules.  

Specifically, the Australian entities can nominate a single entity to file the GIR for the whole group – either: 

1. A designated local entity (DLE) in Australia that lodges the GIR with the ATO for the group, or
2. The ultimate parent entity (UPE) or another designated filing entity (DFE) that lodges the GIR in a foreign jurisdiction (typically the parent’s home country). 

The key point is that it is intended that only one GIR needs to be filed per MNE group. The GIR is informational only. 

2. Foreign lodgement notification  

This is a notification form to inform the ATO when the GIR has been filed overseas by a foreign group entity. The notification ensures the ATO knows that a GIR was filed offshore and they can expect to receive it via an information exchange with the relevant qualified filing jurisdiction. 

3. Australian income inclusion rule (IIR)/undertaxed profits rule (UTPR) tax return (AIUTR) 

This is the Australian Pillar Two Tax return for global minimum tax. This return will report and create an assessment for any IIR top-up tax and UTPR top-up tax amounts that an Australian entity owes for the year under the Pillar Two rules.  

Even if the calculated IIR/UTPR top-up tax is zero, an in-scope Australian entity is required to lodge an AIUTR (it is a nil return in that case). The IIR top-up tax and UTPR top-up tax are the 15 per cent global minimum tax on the undertaxed profits of foreign group members. For groups with no Australian IIR/UTPR tax, for example, because the Australian entities are not parents or a higher-tier parent already applied the IIR, the AIUTR still must be lodged unless an exemption applies as part of the Transitional Relief provisions. 

4. Australian domestic minimum tax (DMT) return (DMTR)  

This is the Australian domestic minimum tax return. This return reports and creates an assessment for any domestic top-up tax (15 per cent minimum tax on low-taxed profits in Australia itself) for the MNE group. Each Australian group entity that has an Australian DMT top-up tax amount for the year (including nil) must lodge a DMTR.  

Sample forms are now available 

On 26 November 2026, the ATO updated its Pillar Two website guidance in relation to the lodgement, payment and other reporting obligations content to include a sample of the Australian Pillar Two standardised combined compliance forms. 

The sample forms combine the foreign lodgement notification, AIUTR, and DMTR into a single form on the basis these are all Australia-specific. An entity will then lodge one of two combined forms depending on whether it is lodging as a standalone entity (Group Entity) or as a designated local entity on behalf of other Group Entities. 

1. View a sample combined global and domestic minimum tax return for a Group Entity here 
2. View a sample combined global and domestic minimum tax return for a designated local entity (DLE) here. 

The sample forms have been designed in consultation with external stakeholders via the ATO’s Pillar Two Global and Domestic Minimum Tax Working Group and a Digital Service Provider working group. The goal is to have these electronic forms available in Online Services for Business/Agents and compatible business software well before the first due date (30 June 2026 for a fiscal year end date of 31 December 2024).  

Importantly, the GIR is a global information return and is not Australian specific. Australian entities who have an obligation to lodge a GIR will need to do so as a separate filing in line with the OECD’s standardised GIR template and XML scheme format. 

Lodgement due dates 

The Australia Pillar Two filing deadlines are extended compared to usual tax return deadlines, reflecting the complexity of gathering global data.  

For the first compliance reporting period the GIR, foreign notification, AIUTR, and DMTR are due 18 months after the end of the first Pillar Two fiscal year, and 15 months after the end of each subsequent fiscal year. The ATO’s guidance provides a schedule of initial due dates for various year-ends.  

In addition to the release of the combined compliance forms, the ATO has to date also released various compliance guidelines to assist taxpayers with understanding and preparing for their Pillar Two calculation and reporting obligations including: 

1. Practical Compliance Guideline PCG 2025/4 outlining the ATO’s transitional practical administrative approach to Pillar Two lodgement obligations and penalties 
2. Draft Legislative Instrument LI 2025/D17 which outlines specific circumstances when the global and domestic minimum tax return lodgements will not be required because they could only ever disclose a nil liability. This does not include the requirement to lodge a GIR, if applicable 
3. ATO guidance on lodging, paying and other obligations for Pillar Two. 

The ATO Pillar Two Working Group are also preparing further compliance reporting content and updates to assist taxpayers to be included on their global and domestic minimum tax webpage in December. 

How BDO can help 

If you would like further information or support in relation to Pillar Two, please reach out to your local BDO corporate and international tax adviser. Alternatively, further information in relation to the measures can be found in BDO’s previous Pillar Two articles.