On 9 May 2023, the Treasurer announced in the 2023–24 Budget that the Australian Government will implement the Organisation for Economic Cooperation and Development (OECD) Global Anti-Base Erosion (GloBE) Model Rules (also known as global minimum tax) and a domestic minimum tax.
This measure is not yet law and new legislation will be introduced.
The purpose of this working group is to co-design and discuss technical considerations for implementation of the measure, ensuring alignment with the ATO’s requirements and standards as well as providing a good user experience.
This meeting was held via webinar on Wednesday 11 September 2024.
Key outcomes
Below is a summary of the key meeting outcomes. Note: the full outcomes are available in the DSP Hub.
At this meeting, discussion points were:
Data points for the draft domestic form
The development of the Australian domestic forms is required to enable triggering Australia's domestic lodge and pay provisions, as the GloBE Information Return (GIR) is an information only return.
The group were guided through the second iteration of the draft Australian domestic form.
The ATO intends on delivering the 3 domestic forms required as one package:
• Foreign notification form
• Australian Income Inclusion Rule (IIR)/ Undertaxed Profits Rule (UTPR) form
• Australian A domestic minimum tax (DMT) form
The ATO recommended reporting the majority of required information within the GIR, rather than domestic lodgments. The intent is to leverage available data and reduce the burden as much as possible.
Upcoming OECD led consultations in relation to the GIR and XML schema may impact the current draft data points. The design of the ATO form is still underway.
Current thoughts on channel offerings
Current system design issues that may impact DSPs.
The project team are working through the best way to support separate domestic lodgment obligations in one form.
The ATO is considering feedback from DSPs to support a wholesale service offering (API or SBR) as well as an ATO Online service offering.
Consultation with DSPs on Pillar 2 changes will continue through to March 2025, with draft guidance availability is anticipated in June 2025, and a go live date of March 2026.
Next steps
The group will reconvene as further information becomes available.
For any questions about Australia’s adoption of the implementation of global minimum tax and domestic minimum tax working group, please raise a ticket in the DSP service desk.
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