In 2024, the Australian Government introduced a 15 per cent minimum tax for large companies.

The laws are based on rules agreed with the OECD Inclusive Framework.

The OECD rules make sure large companies pay an effective tax rate of at least 15 per cent.

Further minor changes need to be made to the law to keep it consistent with the OECD rules.

The changes are based on OECD Administrative Guidance on the rules.

We are consulting on these changes.

The changes:

  • clarify the operation of Australia’s domestic minimum tax in relation to stateless entities with an Australian nexus

  • refine the interaction between Australia’s domestic minimum tax and existing consolidation rules

  • ensure covered taxes are allocated consistent with the allocation of GloBE income for certain entities

  • ensure that Australia’s domestic minimum tax will function properly

  • add a foreign currency translation rule.

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Timeline

  • Opened
    open
    16 February 2026
  • Closes
    pending
    13 March 2026

Contact us

If you have questions, email [email protected]