Client Alert

Australian “Pillar Two” multinational alternative minimum tax draft rules released

By:
Sandie Boswell,
Daniel Kave,
Murat Cihanger,
Brett Curtis,
Yan Wong
25 Mar 20242 min read
On 21 March 2024, the Federal Treasury released a package of Exposure Draft bills and Explanatory Memoranda in respect of the OECD Pillar Two global/domestic alternative minimum tax rules in two separate sites together with accompanying explanatory materials and a discussion paper as linked below.
Contents

International taxation – global and domestic minimum tax – primary legislation

International taxation – global and domestic minimum tax – subordinate legislation  

Global and domestic minimum taxes: interactions with other Australian tax laws – Consultation Paper 

Broadly, this package implements a 15 per cent global minimum tax and domestic minimum tax on Multinational Enterprises with annual turnover of at least EUR750 million.

The domestic and Global Base Erosion (GloBE) alternative minimum taxes are intended to commence for ‘Fiscal years’ starting on or after 1 January 2024.

The Undertaxed Profits Rules are intended to commence for ‘Fiscal years’ starting on or after 1 January 2025.

Submissions to Treasury on the ‘primary’ materials are due by 16 April 2024.

Submissions to Treasury on the ‘subordinate’ materials are due by 16 May 2024.

Grant Thornton will be releasing various commentary on this package in the coming weeks.

Multinationals, especially those headquartered in Australia, should now undertake more specific analysis on this package of draft measures.

In the interim, please contact your Grant Thornton representative or the persons below if you wish to discuss this matter further.

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Authors
  • Sandie Boswell
    Sandie Boswell Sandie has more than 20 years’ experience in the field of R&D Incentives and Government programs both in Australia and the region. View Profile
  • Daniel Kave
    Daniel Kave Daniel, with vast experience, specialises in advising public companies and large private groups on complex tax matters including tax consolidations, M&A structuring, due diligence, corporate structuring, tax planning, capital gains tax, and international tax. He serves multinational organizations and advises businesses in retail, franchising, manufacturing, and mining. View Profile
  • Murat Cihanger
    Murat Cihanger Murat advises on complex tax issues including mergers and acquisitions, income tax, capital gains tax, tax consolidation, tax effect accounting, international tax structuring and management of large tax compliance projects. View Profile
  • Brett Curtis
    Brett Curtis With over 30 years experience in the Australian, UK and New Zealand markets, Brett has expertise across a broad range of corporate and international taxation issues. View Profile
  • Yan Wong
    Yan Wong Yan has 25 years’ corporate and international tax experience with a number of Big Four and Mid-Tier International Chartered Accounting firms. View Profile

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