ATO’s transitional approach to Pillar Two lodgement obligations – draft guidance released

As highlighted by Alia Lum, Amanda Maguire and Debbieann Silcocks, the guidance outlines the Pillar Two lodgement requirements and seeks to implement the OECD’s transitional penalty relief. Also released is an update to guidance on private binding rulings as they relate to Pillar Two matters.

The Australian Taxation Office (ATO) has released draft guidance which outlines the ATO's transitional approach and expectations in relation to the new Australian Pillar Two lodgement obligations as PCG 2025/D3. The Australian lodgement obligations comprise the following: GloBE Information Return (GIR); GIR foreign notification form (FNF) – if the GIR is lodged overseas; Income Inclusion Rule (IIR) / Undertaxed Profits Rule (UTPR) return (AIUTR) – if applicable; and Domesti...

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Authors: Alia Lum, Amanda Maguire,

Published Date: 17 July 2025