On 21 March 2024, the Federal Treasury released a package of Exposure Draft bills and Explanatory Memoranda in respect of the OECD Pillar Two global/domestic alternative minimum tax rules in two separate sites together with accompanying explanatory materials and a discussion paper as linked below.
Contents

International taxation – global and domestic minimum tax – primary legislation

International taxation – global and domestic minimum tax – subordinate legislation  

Global and domestic minimum taxes: interactions with other Australian tax laws – Consultation Paper 

Broadly, this package implements a 15 per cent global minimum tax and domestic minimum tax on Multinational Enterprises with annual turnover of at least EUR750 million.

The domestic and Global Base Erosion (GloBE) alternative minimum taxes are intended to commence for ‘Fiscal years’ starting on or after 1 January 2024.

The Undertaxed Profits Rules are intended to commence for ‘Fiscal years’ starting on or after 1 January 2025.

Submissions to Treasury on the ‘primary’ materials are due by 16 April 2024.

Submissions to Treasury on the ‘subordinate’ materials are due by 16 May 2024.

Grant Thornton will be releasing various commentary on this package in the coming weeks.

Multinationals, especially those headquartered in Australia, should now undertake more specific analysis on this package of draft measures.

In the interim, please contact your Grant Thornton representative or the persons below if you wish to discuss this matter further.

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