ATO updates Pillar Two lodgment and payment guidance: what groups need to know

The Australian Taxation Office (ATO) updated its guidance on lodging, paying and other Pillar Two obligations on 4 August 2026. The update adds new sections on how to lodge the GloBE Information Return (GIR), deregistered entities, and credit transfer and refund requests. It also expands the section on GloBE joint ventures. The guidance now provides a detailed operational picture of Australia's global and domestic minimum tax compliance machinery.

Four lodgment requirements

Consistent with the OECD's GloBE Model Rules, Australia imposes four lodgment requirements on in-scope multinational enterprise (MNE) groups:

1. The GloBE Information Return (GIR), an OECD-developed information return containing data to support risk assessment and verification of top-up tax liabilities.

2. A foreign lodgment notification, required where the GIR is filed with a foreign tax authority rather than the ATO.

3. The Australian IIR/UTPR Tax Return (AIUTR), covering Australian income inclusion rule and undertaxed profits rule liabilities.

4. The Australian DMT Tax Return (DMTR), covering domestic minimum tax liabilities.

The foreign lodgment notification, AIUTR and DMTR are consolidated into a single form: the Combined Global and Domestic Minimum Tax Return (CGDMTR). The GIR is lodged separately. Completing the relevant section of the CGDMTR satisfies each of the three individual lodgment requirements it contains.

The CGDMTR is accessible through Online services for business and Online services for agents. Access requires strong or standard myID identity strength. Groups can also lodge via API-enabled software; specifications are available from the ATO API Portal or by emailing [DPO@ato.gov.au](mailto:DPO@ato.gov.au).

A designated local entity (DLE) lodging on behalf of group entities faces a platform limit of 20 entities (including the DLE itself) in ATO online services. Groups exceeding that threshold must use the API channel, which supports lodgments for up to 300 entities. DLEs lodging for more than 300 entities should contact the ATO at [Pillar2Project@ato.gov.au](mailto:Pillar2Project@ato.gov.au).

How to lodge the GIR

The GIR must be submitted as a validly generated XML file, typically produced by business management or tax reporting software. Digital service providers can access the GloBE Information Returns (GIR) OECD 2026 specification v1.0. All GIRs lodged in Australia must include the Bulk Business Document Message (BBDM) wrapper before lodgment; further detail is available in the Bulk Data Exchange common information artefacts guidance.

The GIR XML file must be lodged through:

Online services for business using the file transfer function, or
Online services for agents using the file transfer function.

Lodging the XML file generates a submission receipt, but acceptance is not immediate. The ATO runs a separate data validation process. An automated email is sent to the contact address provided at lodgment, confirming acceptance (with or without alerts), or advising that the lodgment has failed and must be resubmitted with critical errors corrected. Groups that do not receive a confirmation email within seven days should contact [Pillar2Project@ato.gov.au](mailto:Pillar2Project@ato.gov.au).

Filing the GIR overseas

Where an MNE group's ultimate parent entity (UPE) or designated filing entity (DFE) lodges the GIR with a foreign tax authority, Australian group entities are discharged from their local GIR obligation only if three conditions are met. The GIR must be lodged on time in the foreign jurisdiction; that jurisdiction must have a Qualifying Competent Authority Agreement (QCAA) in effect with Australia; and a foreign lodgment notification (contained in the CGDMTR) must be given to the ATO. If the GIR is not subsequently exchanged with the ATO within the time period specified in the QCAA, the ATO may require local lodgment by written notice.

Australia became a signatory to the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA) on 28 January 2026. Australia's bilateral exchange relationships activated under the GIR MCAA are listed on the OECD Exchange relationships page.

Special rules for 2024 fiscal year GIR lodgments

Australia is a 2024 implementing jurisdiction. In-scope MNE groups whose first applicable fiscal year ends on or before 31 December 2024 must lodge the GIR by 30 June 2026. On 18 May 2026, the OECD released Global Minimum Tax: Support for Central GloBE Information Return Filing and Exchange (2024 Reporting Fiscal Year). In line with that common understanding, the ATO will not request local lodgment nor impose penalties before the relevant GIR exchange deadline where: there is no activated QCAA exchange relationship between Australia and the foreign jurisdiction; the GIR is lodged on time in a 2024 implementing jurisdiction listed in the Annexe to that document; and a foreign lodgment notification has been filed.

Regardless of where the GIR is filed, all Australian group entities retain their own AIUTR and DMTR obligations.

Designating a local entity

An MNE group may nominate a DLE to lodge the GIR, foreign lodgment notification, AIUTR and DMTR on behalf of Australian group entities. A DLE must be a group entity that is GloBE-located in Australia for the fiscal year, must be nominated by every relevant group entity, and must not be an excluded entity or a permanent establishment. There is no specific nomination form. The DLE is identified in the relevant sections of both the GIR and the CGDMTR, and each group entity must maintain written internal records of its nomination.

Where no DLE is appointed, or where a DLE is appointed only for the GIR but not the CGDMTR, each entity with a lodgment obligation must file individually.

Lodgment due dates

The GIR, foreign lodgment notification, AIUTR and DMTR share common due dates:

18 months after the end of the first applicable fiscal year (this extended period applies only to MNE groups in scope from the first applicable fiscal year; later entrants have 15 months).
15 months after the end of each subsequent fiscal year.

For groups with a 31 December 2024 year-end, the lodgment due date is 30 June 2026. Due dates step forward by one month for each subsequent month-end; a 30 June 2025 year-end, for example, gives a deadline of 31 December 2026.

The Commissioner may extend the AIUTR and DMTR deadline but has no power to extend the GIR or foreign lodgment notification deadline.

An automatic 30-day deferral applies to AIUTR and DMTR lodgments for the first fiscal year (commencing in 2024) for all in-scope taxpayers. No automatic payment deferral accompanies this; any top-up tax due in that first year remains payable by the original due date. Further lodgment deferrals, and all payment deferrals, require a formal application using the relevant ATO forms (NAT 75810 for lodgment; NAT 75813 for payment) submitted via practice mail (for tax agents) or secure mail (for DLEs and group entities). An automatic 30-day suspension of lodgment enforcement action also applies to foreign lodgment notifications for the first fiscal year.

The ATO cannot defer GIR or foreign lodgment notification deadlines, but may agree to suspend lodgment enforcement action during the transition period (fiscal years commencing on or before 31 December 2026 and ending on or before 30 June 2028) for generally no longer than four weeks, in accordance with PCG 2025/4.

Registration

No pre-registration is required. When the first CGDMTR is received, the ATO automatically creates a Global and Domestic Minimum Tax (GDMT) account and role. Tax agents already linked at income tax account level can lodge the CGDMTR without further steps. Where a group needs to nominate a new tax agent not already linked at income tax level, it should request account and role creation via secure mail in Online services for business before lodgment.

Exemptions from lodgment

The Commissioner's Legislative Instrument LI 2025/28 (*Taxation Administration (Exemptions from Requirement to Lodge Australian IIR/UTPR Tax Return and Australian DMT Tax Return) Determination 2025*, registered 22 December 2025) sets out circumstances in which group entities are exempt from lodging the AIUTR and DMTR. The instrument is aimed at entities whose top-up tax liability will always be nil. The Commissioner cannot exempt entities from lodging the GIR or foreign lodgment notification.

DMTR exemptions can apply to, among others: certain subsidiary members of tax consolidated groups or MEC groups; entities not GloBE-located in Australia (other than stateless constituent entities created in Australia or main entities of an Australian GloBE permanent establishment); certain GloBE securitisation entities; and certain flow-through entities that cannot incur an Australian DMT liability.

AIUTR exemptions require two cumulative conditions to be met. The first concerns IIR: the entity must be, broadly, not a parent entity, or a parent entity not GloBE-located in Australia, or a parent entity whose IIR exposure is displaced by a higher-tier qualified IIR. The second concerns UTPR: the entity must, broadly, be a subsidiary member of a consolidated group, not GloBE-located in Australia, shielded by qualified IIR or transitional UTPR safe harbour coverage, or an investment or securitisation entity of a defined type. Both conditions must be satisfied; neither alone is sufficient. Entities that meet lodgment exemptions must still keep records demonstrating that they qualify.

Obligations for specific entity types

GloBE permanent establishments. All lodgment and payment obligations rest with the main entity. The main entity must give the Commissioner a GIR, AIUTR and DMTR in respect of any Australian GloBE permanent establishment.

GloBE joint ventures. GloBE JVs and GloBE JV subsidiaries are not required to lodge the GIR or AIUTR separately. However, MNE groups holding ownership interests in GloBE JVs must include disclosure information about them in the GIR. GloBE JVs and their subsidiaries do have a single DMTR lodgment obligation under section 127-55 of the Taxation Administration Act 1953. This can be satisfied either by appointing a DLE of one of the broader MNE groups (noting that a GloBE JV of two MNE groups may appoint only one DLE), or by lodging standalone DMTRs. Where a GloBE JV has a different fiscal year from its parent MNE group, it should only appoint a DLE with the same fiscal year-end.

Accounting joint operations. There is no concept of a joint operation under the GloBE Rules. Whether such an arrangement carries lodgment obligations turns on whether it constitutes a constituent entity. If it does, standard lodgment obligations apply. Certain flow-through entities that are joint operations created in Australia may be eligible for AIUTR and DMTR exemptions under LI 2025/28. The ATO will also accept GIRs that do not list certain joint operations as separate constituent entities, provided specific conditions are met, including that participants report their proportionate share of the joint operation's income and covered taxes in their own GIR disclosures.

Deregistered entities. A deregistered company ceases to exist as a legal entity and cannot be included in the CGDMTR as a group entity or lodge on a standalone basis, though it can still appear in the GIR. Where a deregistered company has a top-up tax liability, groups should contact [Pillar2Project@ato.gov.au](mailto:Pillar2Project@ato.gov.au) before lodging. Where a CGDMTR has already been lodged including a deregistered entity, the ATO may cancel that entity's specific form; no further action is generally required unless the ATO makes contact.

Unincorporated entities. Subdivision 128-B of Schedule 1 to the Taxation Administration Act 1953 extends lodgment and liability obligations to trustees (for trusts), partners (for GloBE partnerships), and the relevant group entities or partners (for unincorporated GloBE JVs and their subsidiaries).

Liabilities and joint and several liability

Top-up tax liabilities arise on the day the relevant return's due date falls. All three charges, Australian IIR tax, UTPR tax, and DMT tax, bring a jurisdiction's effective tax rate up to 15%. Shortfall interest charge, general interest charge, and penalties can also apply.

Under section 128-5 of Schedule 1 to the Taxation Administration Act 1953, every group entity of an MNE group is jointly and severally liable for any top-up tax, general interest charge, shortfall interest charge, or penalties payable by any other group entity. The ATO may therefore collect from any entity in the group. Additional joint and several liability rules apply to group entities that hold direct ownership interests in GloBE JVs. Exceptions apply where the conditions in subsection 820-39(3) of the Income Tax Assessment Act 1997 are met, or where Australian law prohibits the relevant entity from entering into such an arrangement.

Payments and credit transfers

A payment reference number (PRN) is issued for each group entity when any top-up tax liability is greater than nil. The same PRN applies to all three liabilities. It is provided on the lodgment confirmation page or success message. A DLE may make payments on behalf of group entities but must use each entity's own PRN; failure to do so risks processing delays.

The credit transfer and refund functions available for other tax accounts are not currently available for the GDMT account through ATO online services. To request a credit transfer or refund, groups and agents should phone 13 28 66 (businesses) or 13 72 86 (registered tax agents), or email [Pillar2Project@ato.gov.au](mailto:Pillar2Project@ato.gov.au).

Periods of review and record keeping

A four-year period of review applies to global and domestic minimum tax assessments. For AIUTR assessments, the period runs from the later of the date the GIR and the AIUTR are given to the Commissioner. For DMTR assessments, it runs from the later of the date the GIR and the DMTR are given to the Commissioner. The period may be extended by Federal Court order or by written agreement.

All Australian group entities, GloBE JVs and their subsidiaries must keep records in English (or in a format readily convertible to English) that fully explain their compliance with the legislation. Records must be retained for the longer of eight years from preparation or eight years from completion of the relevant transactions, or to the end of any extended period of review. Excluded entities not required to lodge must still keep records evidencing their excluded status. Entities relying on LI 2025/28 exemptions must keep records demonstrating that they qualify.

Penalties

The uniform penalty provisions in Schedule 1 of the Taxation Administration Act 1953 apply, with base penalty amounts calibrated to the significant global entity scale. Failure to lodge on time attracts a base penalty multiplied by 500. False or misleading statements, or positions that are not reasonably arguable, attract a doubled base penalty. A separate penalty applies for failure to keep adequate records.

The OECD has recommended that administrators provide a soft landing during the transition period, declining to apply penalties where an MNE group has taken reasonable measures to apply the GloBE Rules correctly. The ATO's PCG 2025/4 sets out its approach to penalty enforcement during the transition period, which covers fiscal years commencing on or before 31 December 2026 and ending on or before 30 June 2028.

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