Australia: Closed consultation on the primary legislation to implement the OECD's Pillar Two (Minimum Tax Rate)

On 16 April 2024, the Australian Treasury closed the consultation on the primary legislation to implement the OECD's Pillar Two global Minimum Tax Rate. The legislation is aligned with the OECD's Pillar Two framework. The legislative proposal aims to introduce a 15% top-up tax for multinational enterprises (MNEs) and sets out the framework and details of how the tax would be applied to MNEs to ensure that they meet their minimum tax obligations both globally and domestically. To facilitate the implementation of this measure, the materials include exposure draft primary legislation, subordinate legislation in the form of regulations and detailed explanatory documents. The primary legislation includes an Imposition Bill to enforce the tax payable under the global and domestic minimum taxes, an Assessment Bill outlining the obligations and framework for these taxes, and a Consequential Amendments Bill to address the necessary administrative provisions. These Bills are accompanied by an Explanatory Memorandum to provide clarity on their scope and intent.