Key implementation point
UTPR applies from 2025, one year after IIR/ADMT. Non-refundable R&D offset for large companies reduces GloBE covered taxes.
Implementation detail
- 01 Australia enacted the Global Minimum Tax Act 2024, broadly following the OECD model rules.
- 02 ADMT (Australian QDMTT) applies to Australian constituent entities from 1 January 2024.
- 03 UTPR enacted but applies from 1 January 2025.
- 04 Australia-specific: R&D tax incentive offset (refundable for SMEs, non-refundable for large companies) — non-refundable credits reduce covered taxes.
- 05 Australian thin capitalisation rules interact with GloBE income determination.
- 06 ATO (Australian Taxation Office) issued detailed Law Companion Ruling and guidance notes.
- 07 Australia is a significant UPE jurisdiction for resources-sector MNEs.
Enacted legislation
Taxation (Multinational Global and Domestic Minimum Tax) Act 2024
Official sources & further reading
Track Australia rules against your live MNE
In Pillar2OS you can pull this jurisdiction's rules directly into your entity structure — automatically calculating top-up positions, flagging QDMTT obligations, and tracking rule changes as they happen across all your operating countries.
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