Australia Pillar Two lodgement exemptions finalised

The filing exemptions provided by the ATO are reasonable overall, given the approach of the ATO to only provide an exemption in circumstances where there can never be a top-up tax liability, as detailed by Alia Lum and Amanda Maguire.

The Australian Taxation Office (ATO), on 22 December 2025, finalised the rules relating to the exemptions from filing Australian Pillar Two returns, being the domestic minimum tax (DMT) return and Australian Income Inclusion Rule (IIR)/ Undertaxed Profits Rule (UTPR) returns. These rules are set out in a legislative instrument, Taxation Administration (Exemptions from Requirement to Lodge Australian IIR/UTPR Tax Return and Australian DMT Tax Return) Determination 2025 (the Determination). T...

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Authors: Alia Lum, Amanda Maguire

Published Date: 02 February 2026