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Treasury released for consultation draft legislation implementing key aspects of the OECD’s Pillar Two global minimum tax rules.

The first set is the , which contains three draft bills that form part of a set of legislation required to implement the Pillar Two global anti‑base erosion (GloBE) rules and a domestic minimum tax in Australia:

• , which imposes the tax payable under the global and domestic minimum taxes
• , which establishes the liability and framework for the global and domestic minimum taxes
• , which contains consequential and miscellaneous provisions necessary for the administration of the global and domestic minimum taxes

The second set is the , which contains the Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024 implementing the domestic framework for a multinational top-up and including the detailed calculations required to arrive at a liability to top-up tax.

´¡Ìý has also been included to assist stakeholders in providing feedback on interactions between the exposure draft primary legislation and provisions in Australia’s existing income tax law, including:

• Hybrid mismatch rules;
• Controlled foreign company (CFC) rules
• Foreign income tax offsets

The core rules for implementation of the Pillar Two rules would be effective from 1 January 2024.

Consultation on the primary legislation closes 16 April 2024, and consultation on the subordinate legislation closes 16 May 2024.

Read a March 2024 report prepared by the ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø member firm in Australia