Australia has made a series of amendments to its Global and Domestic Minimum Tax Rules, bringing domestic law into closer conformity with the OECD's Pillar Two framework.
The changes are described as minor in character. Their primary purpose is to ensure consistency with OECD rules and guidance, incorporating elements from the Agreed Administrative Guidance issued in December 2023, June 2024, and January 2026.
The amendments cover six areas:
- Flow-through entity income allocation rules
- The Blended CFC Allocation Key
- The substitute loss carry-forward rule
- Extension of the transitional CbCR Safe Harbour by 12 months, to fiscal years beginning prior to 31 December 2027
- CbCR Safe Harbour adjustments for Investment Entities and Insurance Investment Entities
- QDMTT Safe Harbour coverage for Stateless Constituent Entities
Because the amendments align Australian law with the underlying OECD rules, they apply retroactively to fiscal years commencing on and after 1 January 2024. Groups with Australian constituents should review each of these areas against their existing Pillar Two compliance positions for open periods.