Australia signs the information exchange for GloBE Information Return (GIR)
11/02/2026
On 28 January 2026, Australia reached an important milestone in its implementation of Pillar Two by becoming a signatory to the Multilateral Competent Authority Agreement (MCAA) on the exchange of GloBE Information Return (GIR). As a result, once a GIR is lodged in Australia, it does not need to be re-lodged in other signatory jurisdictions.
The GIR MCAA is an international agreement developed by the Organisation for Economic Co-operation and Development (OECD) and Group of 20 (G20) Inclusive Framework to support the implementation of the Pillar Two rules. It facilitates the automatic exchange of the GIR, a standardised set of data that enables tax authorities, such as the Australian Taxation Office (ATO), to assess whether multinational enterprise (MNE) groups are subject to a global minimum tax rate of 15% in each jurisdiction.
With Australia becoming a signatory, an MNE Group would be able to simplify and reduce its lodgement obligations across the jurisdictions in which it operates in by filing a single, centralised GIR. This GIR would be automatically shared with other signatory jurisdictions under exchange-of-information arrangements in accordance with the MCAA and the agreed dissemination approach under the OECD Inclusive Framework, rather than requiring separate filings by a designated local entity in each jurisdiction.
As of 2 February 2025, 26 countries, including United Kingdom, New Zealand, Japan, France, and Germany, have signed up to the MCAA, with more expected to do so before the first lodgement due date of 30 June 2026 for MNE Groups with an income year ending 31 December 2024.
A full list of signatory countries to the MCAA can be tracked here. Under the Tax Administration Act 1953, the group entities can nominate one entity (i.e. designated local entity or designated foreign filing entity) in the MNE Group to lodge one single GIR. This nomination is lodged in the first year with the ATO through a foreign lodgement notification form.
Note that neither China nor the United States (US) has implemented Pillar Two. Refer to our previous coverage on the ‘Side-by-Side’ (SbS) arrangement for further details.
How SW can help
We can assist in undertaking country-by-country analysis of the obligations and consideration of the application of exemptions and safe harbour rules.
We can also support the implementation of SW’s CTS Pillar Two software to facilitate the lodgement of the GloBE Information Return and other lodgement obligations.
In addition, we can help MNE groups assess the impact of the SbS arrangement and anticipated Australian legislative changes, identify data and systems gaps, evaluate safe harbour eligibility, and develop practical compliance strategies to manage ongoing Pillar Two obligations and costs.
