Pillar Two

What Australia’s 2025 international tax changes mean for your cross‑border strategy

From the introduction of Pillar Two to increased debt deduction limitations and public reporting obligations, the international tax landscape is shifting rapidly.

OECD releases Pillar Two Side-by-Side Package and what it means for multinational groups

OECD announces the ‘Side-by-Side’ administrative guidance package

Australian tax filing obligations for Pillar Two rules

The Australian Pillar Two Rules align with the OECD’s initiative to ensure MNEs pay a minimum Effective Tax Rate (ETR) of 15 per cent globally.

Pillar Two rules in Australia passed

Australia's Parliament has passed the Pillar Two rules, aligning with the OECD's global initiative to establish a 15% minimum tax rate for large multinational enterprises (MNEs).

Pillar 2 Primer - Are you prepared?

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

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.

Global minimum 15 per cent corporate tax rate – Australia moves closer to implementation

The imposition of a 15 per cent global minimum tax for multinational corporate groups appears imminent but there is still a lot of work to do to finalise details. Here’s what we know so far and how it may impact multinational businesses including pillar 2, GloBe and Safe harbour considerations.

Global Minimum Corporate Tax Rate – Pillar Two – will it happen?

In October 2021, over 135 jurisdictions (including Australia) joined a ground-breaking plan to update key elements of the international tax system. The Global Anti-Base Erosion Rules (GloBE) are intended to ensure large multinational enterprises pay a minimum level of tax on the income arising in each of the jurisdictions where they operate. The OECD released the Pillar Two Model Rules on 20 December 2021, and Commentary to accompany the Rules on 14 March 2022. Further guidance is expected by way of an Implementation Framework, but that may not be completed and available until the end of 2022.