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Pillar Two

Pillar Two introduces a global minimum tax that significantly impacts multinational groups, bringing new compliance and reporting challenges.

SW Accountants & Advisors are specialists in Pillar Two, combining deep technical expertise with practical, commercial advice. We support businesses in understanding their obligations, managing risk, and implementing compliant and efficient solutions.

This page brings together our Pillar Two insights and articles to help you navigate the rules with confidence. For tailored advice, contact SW Accountants & Advisors to speak with our Pillar Two experts.

Article Pillar Two ‘Side-by-Side’ arrangement released by OECD   On January 5, 2026, the OECD announced a new ‘Side-by-Side’ (SbS) agreement, crafted to address concerns raised by the United States about the global minimum tax rules. The deal introduces administrative guidance and extends safe harbour mechanisms, aiming to simplify compliance for multinational enterprises (MNEs).   While the United States (US) is the first to qualify, other countries may also […] 08/01/2026
Events Practical Guidance on Complying with the Global and Domestic Minimum Tax (Pillar Two) Regime Join our interactive seminar and stay ahead on the latest Pillar Two developments. Join us in Sydney for our in-depth Pillar Two seminar, delivered by SW tax experts Daren Yeoh (Partner and Corporate & International Tax Director), Kirsty McDonnell (Tax Director), Antony Cheung (Associate Director). This interactive session will provide practical guidance on the OECD’s […] 25/09/2025
Article Preparing for Pillar Two | CTS Pillar Two If you’re part of a multinational enterprise group operating in Australia, new Global and Domestic Minimum Tax (Pillar Two) lodgement requirements are on the horizon. From 30 June 2026, Australian subsidiaries, consolidated groups, and joint ventures will need to determine whether they fall within scope, and when exemptions apply. At SW, we’re already helping clients […] 05/09/2025
Article ATO releases exemptions for Australian domestic Pillar Two forms The ATO has released draft Legislative Instrument LI 2025/D17, which specifies when certain entities are exempt from lodging domestic Pillar Two forms. However, this exemption does not apply to the Global Information Return (GIR). The purpose of the instrument is to help multinational enterprise groups reduce compliance costs by removing the need to lodge certain […] 03/09/2025
Article Pillar Two obligations in Australia during the transition period The ATO released new guidance helping large multinational companies navigate their obligations under Pillar Two tax rules. While these companies face additional paperwork and potential penalties, the ATO is taking a lenient approach during the transition period for businesses making genuine compliance efforts. Overview Draft Practical Compliance Guideline PCG 2025/D3 outlines the ATO’s transitional compliance […] 22/08/2025
Article Updates on the Big Beautiful Section 899 & Pillar Two  Never a dull moment in US politics and tax policies – the proposed section 899 has come and gone in a matter of weeks. What are the ramifications for Pillar Two?  Just few weeks after the US Congress passed the One Big Beautiful Bill Act (the OBBBA), including the controversial Section 899 ‘revenge tax’, the […] 02/07/2025
Article Pillar Two FAQs: Key Insights on the Global Minimum Tax Pillar Two introduces a global minimum tax framework aimed at ensuring multinational enterprises pay a fair level of tax, regardless of where they operate. This FAQ section addresses key questions about its implementation, impact on businesses, and compliance requirements. Whether you’re looking for insights on effective tax rates, reporting obligations, or exemptions, you’ll find clear […] 20/03/2025
Events OECD Pillar Two GloBE rules – Global and domestic minimum tax seminar Our 2023 OECD Pillar Two GloBE rules – Global and domestic minimum tax seminar provided an update of the new requirements impacting multinational groups. Our online seminar was delivered in an interactive format with SW expert Daren Yeoh, Partner and Corporate & International Tax Director. This seminar covered the following topics: SW Speaker Daren YeohPartner […] 24/10/2023
Article Major international tax reform with OECD Two-Pillar approach With increased globalisation and digitalisation creating growing concern about tax avoidance by multinationals, the OECD Two-Pillar approach aims to address international corporate tax challenges. In the 2023-24 Budget, the Government announced the implementation of a 15 per cent global minimum tax and domestic minimum tax, key aspects of Pillar Two of the OECD/G20 Two-Pillar Solution […] 10/05/2023