Pillar Two: Combined Global & Domestic Minimum Tax Returns

Today, the Australian Taxation Office unveiled our first look at its draft Combined Global & Domestic Minimum Tax Return.

While this form is quite overdue (initial expectation was a release in June 2025), it is quite surprising in its simplicity.

This proposed new form combines in one all 3 elements of Pillar Two reporting:

• GloBE Information Return / Foreign Lodgment Notification

• Income Inclusion Rule / Undertaxed Profits Rules Return

• Domestic Minimum Tax Return

Yet, a simple form does not mean a simple regulatory framework. Complex rules still apply in the background to determine the answers reported in the form.

Still, Multinational Enterprise Groups would appear to finally encounter a modest reprieve in the ever-growing rise of compliance.

Let us see how long it takes for this simple form to gain complexity!