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.
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 is scheduled was held via webinar on Wednesday 23 July 2025.
Key outcomes
Below is a summary of the key meeting outcomes. Note: The full outcomes are available in DSP Hub .
General update on implementation of Pillar 2
At this meeting the discussion points were:
- OECD progress on GIR validation rules
- Run through of draft OpenAPI specification (OAS) and product page content
- Summary of changes to SBR services
- User testing insights
- DSG registration and onboarding
- Anticipated timelines
Global and domestic minimum tax guidance on the ATO website was updated in May, providing additional information on how the rules apply, calculating top-up tax, and guidance and examples about lodging, paying and recording keeping obligations.
On 16 July 2025, the following guidance was published and are open for feedback until 29 August 2025:
- draft Practical Compliance Guideline PCG 2025/D3 Global and domestic minimum tax lodgment obligations – transitional approach
- updated Taxation Ruling TR 2006/11DC Private rulings.
The OECD published the GloBE Information Return (Pillar Two) Status Message SML Schema (EN) PDF, 2.2MB) on 30 July 2025 (Paris time) which contains the agreed validation rules.
The Pillar Two information session was held on 15 August 2025. The open information session is primarily aimed at multinational entities (MNEs) and tax advisers who may be affected by the global and domestic minimum tax.
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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