Australian Pillar Two legislation now effective

With the registration of the Pillar Two subordinate legislation on 23 December 2024, the full package of legislation implementing the Pillar Two Global Anti-Base Erosion (GloBE) rules in Australia now has legal effect. This may trigger new current tax disclosures for financial statements.

To recap, the Australian GloBE rules include the following: an Income Inclusion Rule (IIR) which applies for income years starting on or after 1 January 2024; a domestic minimum top-up tax (DMT) which applies for income years starting on or after 1 January 2024; and an Undertaxed Profits Rule (UTPR) which applies for income years starting on or after 1 January 2025. Further background to the Australian Pillar Two rules as well as a brief outline of the OECD Model GloBE Rules (Model Ru...

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Authors: Alia Lum, Peter Oliver,

Denis Larkin
, Amanda Maguire

Published Date: 24 January 2025

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