pillar two Archives - SW Accountants & Advisors

Australia signs the information exchange for GloBE Information Return (GIR)

Stephen Follows — Wed, 11 Feb 2026 04:05:00 +0000

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.

Contributors

Antony Cheung

The post Australia signs the information exchange for GloBE Information Return (GIR) appeared first on SW Accountants & Advisors.

Pillar Two ‘Side-by-Side’ arrangement released by OECD

Stephen Follows — Thu, 08 Jan 2026 00:59:22 +0000

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 be included if they meet the criteria. It is crucial for affected MNEs to understand these changes, as Australia and other jurisdictions are expected to update their rules to align with the new framework.

To recap, a SbS solution to exempt US-parented multinational groups from the Global Anti-Base Erosion (GloBE) Model Rules (i.e. Income Inclusion Rule (IIR) and Undertaxed Profits Rule (UTPR)) was first proposed between the United States and other G7 nations in July 2025 as part of an agreement for the US to drop the implementation of the Section 899 ‘Revenge Tax’ (see SW’s previous coverage).

After months of intense negotiations, the OECD announced that the 147 members within the Inclusive Framework have now agreed to a package in the form of an administrative guidance to the GloBE Model Rules. The OECD document sets out a number of new safe harbours for the purpose of materially simplifying the compliance burden of the GloBE Model Rules and applying the SbS system. The existing transitional Country-by-Country Reporting (CbCR) Safe Harbour has also been extended for a year. The proposed measures are summarised in the table below:

New safe harbours introduced	Relevant dates	Summary
Simplified Effective Tax Rate (ETR) Safe Harbour	Income years commencing 1 January 2027 (or 1 January 2026 in limited circumstances)	• A ‘permanent’ simplified ETR can apply for a tested jurisdiction, provided there were no top-up tax (TUT) for that jurisdiction in the preceding two years. • Simplified ETR is calculated by dividing ‘simplified taxes’ by ‘simplified income’. Where the rate is at least 15%, the TUT is nil. • Notwithstanding the term ‘simplified’, there are still a series of adjustments required – mandatory (e.g. excluded dividends / equity gains, etc), industry specific (e.g. financial services), and optional adjustments. • Amounts are based on financial accounting data to prepare a group’s consolidated financial statements and not CbC report. • MNE groups will need to assess and upgrade their current software and systems to ensure they can accurately calculate and report using the new permanent simplified ETR.
Extension to the Transitional CbCR Safe Harbour	Additional one-year extension (from three years) to include years beginning on or before 31 December 2027	• MNE groups will benefit from an extra year of relief, as the 17% ETR threshold for the CbCR safe harbour will now extend to a fourth year, making compliance easier and reducing tax uncertainty for affected businesses.
SbS Safe Harbour	Income years commencing 1 January 2026	• No TUT is payable under the IIR or UTPR if the ultimate parent entity is located in a jurisdiction with a ‘Qualified SbS Regime’ under the central record. At present, only the US is recorded as satisfying the regime. • Broadly, a qualified regime refers to a jurisdiction that has: – a nominal corporate tax rate of at least 20% – qualified domestic minimum top up taxes (QDMTT) or corporate alternative minimum tax of 15% aligned with minimum taxation objectives – has an eligible worldwide tax system applicable on offshore (active and passive) income of foreign branches and controlled foreign companies – mechanisms to address base erosions and profit shifting – no material risk of an ETR below 15% on domestic and foreign profits. • The QDMTT of a jurisdiction will continue to apply and take precedence • Member jurisdiction can request for its existing tax regimes to be assessed against the eligibility criteria. • US-based groups must continue to follow the existing rules for income years that begin before 1 January 2026.
Ultimate Parent Entity (UPE) Safe Harbour	Income years commencing 1 January 2026	• MNE groups can elect for this safe harbour (which replaces the transitional UTPR safe harbour) such that there is no TUT under UTPR in the UPE jurisdiction, provided that jurisdiction as a ‘Qualified UPE Regime’ (similar to the criteria for SbS safe harbour). • No jurisdiction is currently recorded though the US is expected to qualify. • For completeness, the transitional UTPR safe harbour only applies to the UPE jurisdiction if that jurisdiction has a nominal corporate tax rate of at least 20% and for income years beginning on or before 31 December 2025.
Substance-based tax incentives Safe Harbour	Income years commencing 1 January 2026	• Safe harbour intends to allow MNE groups to continue benefit from certain ‘qualified tax incentives’ (QTI) that are substantially connected to the economic substance for that jurisdiction. • The QTI is added to the adjusted covered taxes but capped at either the greater of 5.5% of eligible payroll costs or depreciation expense in respect of eligible tangible assets, or 1% of carrying value of eligible tangible assets.

Observations and what this means for Australia

In order for the Australian equivalent rules to maintain their qualified status (in other words administering in a manner consistent with the GloBE Model rules), an amendment to the domestic rules to mirror the OECD changes is expected shortly. Practically, the extension of the transitional CbCR safe harbour for an additional one year would allow multinational groups to improve on their systems in extracting information to meet the Pillar Two compliance obligations.

To avoid roll-back of legislations by jurisdictions that have already implemented the Pillar Two rules, the changes introduced under this SbS arrangement will only apply to income years commencing 1 January 2026. Whilst Australia and other jurisdictions may also seek to demonstrate that it qualifies for the SbS and UPE safe harbours, the registration process may be lengthy, and any further exceptions of jurisdictions (other than US) remain to be seen.

Furthermore, the commencement date of these new changes also mean compliance costs will still be significant, given MNE groups (including US-parented groups) are still required to meet their lodgement obligations in jurisdictions that have already implemented the GloBE Model equivalent rules for income years commencing 1 January 2024 and 2025.

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.

Contributor

Antony Cheung

The post Pillar Two ‘Side-by-Side’ arrangement released by OECD appeared first on SW Accountants & Advisors.

Corporate and International Tax update

Sarah Redditt — Wed, 24 Sep 2025 00:38:43 +0000

Our 2025 Corporate and International Tax update seminar ensured you are up to date with the latest developments in corporate and international income tax.

Our seminar was delivered in an interactive online format with SW Tax experts Daren Yeoh, Yang Shi, Kirsty McDonnell and Paul Hum. Our speakers equipped you with invaluable insights into the latest developments and emerging tax issues impacting corporate and international groups.

This seminar explored the following topics:

An update on Pillar Two
The Debt Deduction Creation Rule
Notable recent tax cases including the Pepsi’s case
Changes to the non-resident CGT regime
Recent ATO rulings and guidance
Developments in transfer pricing
Other tax update

SW Speakers

Daren Yeoh
Partner and Corporate & International Tax Director

Kirsty McDonnell
Director, Tax

Yang Shi
Director, Tax

Paul Hum
Director, Tax

The post Corporate and International Tax update appeared first on SW Accountants & Advisors.

Preparing for Pillar Two | CTS Pillar Two

Julia Lee — Fri, 05 Sep 2025 05:19:44 +0000

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 map their entities, minimise compliance costs, and prepare for lodgement with our CTS Pillar Two software.

Why CTS Pillar Two?

CTS Pillar Two is your comprehensive solution for navigating the complex landscape of OECD Pillar Two calculations. As international tax regulations continue to evolve, it’s crucial for businesses to stay ahead of the curve and ensure compliance with the latest standards set by the OECD.

CTS Pillar Two is designed to be user-friendly, highly flexible, and intuitive. It seamlessly integrates with any internal workpapers, ensuring a smooth and efficient workflow.

Key features

General

ATO releases exemptions for Australian domestic Pillar Two forms

Julia Lee — Wed, 03 Sep 2025 06:06:38 +0000

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 global and domestic minimum tax return, where the Commissioner of Taxation considers it to be unnecessary because they could only ever disclose a nil liability.

Streamline your Pillar Two compliance with SW’s CTS Pillar Two software – designed to simplify lodgement of the GIR and domestic forms when exemptions don’t apply.

For more information on the Pillar Two obligations in Australia during the transition period, see our previous alert.

Below are the five main exemption pathways from the requirement to lodge the domestic minimum tax return (DMT).

Exemption to lodge an Australian Income Inclusion Rule (IIR)/ Undertaxed Profits Rule (UTPR) tax return

In addition, the draft instrument grants an exemption from the requirement to lodge the IIR/UTPR tax return, provided all conditions are met:

The Group entity:

is not an Australian-located Parent Entity
is an Australian-located Parent Entity of a wholly Australian group or
is an Australian-located Parent Entity but a higher-tier Parent (intermediate or UPE) is required to apply a QIIR for the year

and any of the following apply:

the Group entity is a subsidiary member of a TC/MEC group
the Group entity is not GloBE-located in Australia and not a GloBE Main Entity for an Australian PE
the Group entity is a GloBE Investment Entity or Insurance Investment Entity
the Group entity is a GloBE securitisation entity meeting the relevant criteria or
any of the group-level “switch-off” scenarios apply, i.e. Australia’s UTPR taxing rights would be wholly extinguished because:
the group’s undertaxed profits are covered by the IIR charging mechanism such that Australia’s UTPR allocation would be zero or
the Transitional UTPR Safe Harbour applies to the UPE jurisdiction and combined with IIR coverage elsewhere and thus reducing Australia’s UTPR allocation to zero.

For completeness, GloBE JVs and JV subsidiaries are not required to lodge an Australian IIR/UTPR tax return.

How we can advise your on Pillar Two with our CTS software

Navigating Pillar Two compliance can be complex, especially when determining which entities are exempt from lodging domestic forms. Our team can advise on your Pillar Two obligations by mapping your entities against the exemption categories each fiscal year. Where exemptions do not apply, we also support the implementation of SW’s CTS Pillar Two software to simplify and manage the lodgement of the Global Information Return (GIR) and Australian domestic forms.

We can assist in mapping your entities against the exemption categories each fiscal year to determine when lodging the relevant domestic forms is not required.

We can also support the implementation of SW’s CTS Pillar Two software to facilitate the lodgement of the GIR and Australian domestic forms, should the exemptions not apply.

In-person Pillar Two sessions will be held in Melbourne and Sydney on 15 and 23 October 2025 respectively. Reach out to your SW contacts for more information.

Contributor

Antony Cheung

The post ATO releases exemptions for Australian domestic Pillar Two forms appeared first on SW Accountants & Advisors.

过渡时期澳大利亚的支柱二义务

Dara Larasati — Tue, 26 Aug 2025 05:58:27 +0000

澳大利亚税务局（ATO）发布了新指南，帮助大型跨国公司履行支柱二税务规则规定的义务。虽然这些公司要处理的文件多了，还有可能面临处罚，但 ATO 会对过渡时期切实开展合规工作的企业宽大处理。

总览

实务合规指南草案 PCG 2025/D3 概述了 ATO 在过渡时期（2026 年 12 月 31 日或之前开始、2028 年 6 月 30 日或之前结束的财政年度）对申报义务和处罚的过渡性合规办法。

澳大利亚实施了 15% 的全球与国内最低税率（支柱二规则），这与支柱二项下的经合组织全球反税基侵蚀（GloBE）规则保持一致。其对象是受测年度之前的四个财政年度内至少有两个财政年度合并收入≥7.5 亿澳元的大型跨国企业（MNE）集团。支柱二规则自 2024 年 1 月 1 日起适用于澳大利亚。

值得注意的是，自 2025 年 1 月 1 日起，未征低税利润规则可能会使澳大利亚的跨国企业集团成员承担其他集团成员的相关补税。这与前者是否对后者拥有任何所有者权益无关。因此，审计人员可能要求对全球集团 2025 财年的情况开展支柱二分析。

澳大利亚的主要申报义务有哪些？

适用的跨国企业集团必须提交以下材料：

GloBE 信息申报表（GIR）– 经合组织计算税务负债的标准化表格。
海外通知表（FNF）– 通知 ATO 海外申报 GIR 的情况。
澳大利亚 IIR/UTPR 纳税申报表（AIUTR）– 根据收入包含规则（IIR）和未充分纳税利润规则（UTPR）评估补税。
澳大利亚国内最低报税表（DMTR）— 对澳大利亚低征税利润进行补税评估。

AIUTR、DMTR 和 FNF 被并入全球与国内统一最低报税表（CGDMTR）。GIR 仍是一项独立的义务。第一年的申报截止日期为财政年度结束后 18 个月，此后为 15 个月。对于以 2024 年 12 月 31 日为财政年度末的跨国企业集团，申报截止日期为 2026 年 6 月 30 日。

重点注意：跨国企业集团的澳大利亚成员必须在澳大利亚履行申报义务，即使集团母公司所在国没有实施支柱二规则。澳大利亚各实体可指定由一家澳大利亚集团实体（称为“指定本地实体”，简称DLE）代表澳大利亚实体提交报税表。

截至本文件发布之日，澳大利亚尚未签署支柱二项下的《关于全球反税基侵蚀信息交换的多边主管机构协议》（MCAA）。在此之前，必须在澳大利亚向 ATO 提交 GIR，即使该 GIR 已在海外提交。

对纳税人的处罚是否会“软着陆”？

在过渡期内，如果跨国企业集团证明自己采取了合理措施遵守有关规定，ATO 将采用“软着陆”办法（即减免罚款）。

以下对这些合理的措施举例说明：

相关实施计划和内部政策有记录可循，
系统升级和差距分析，
积极主动地配合 ATO 和外部顾问，以及
及时纠正错误。

此外，在过渡时期，个别无心之失应该不会被处罚。然而，若以事不关己的态度待之，或未按常理谨慎处理，则可能会受到处罚。目前对大型全球实体实施的行政处罚适用于这些情况。

信永中和如何协助？

我们可以通过以下方式协助贵公司实施支柱二项目：

就支柱二对贵集团的影响提供咨询意见，
专门制定符合贵集团要求的支柱二实施计划，
确定并分类集团内的实体，
就收费机制的适用提供咨询意见，
协助开展过渡性的国别报告安全港计算，以及
采用信永中和的 CTS 支柱二软件进行规划、支柱二计算并提交 GIR 和国内报税表。

The post 过渡时期澳大利亚的支柱二义务 appeared first on SW Accountants & Advisors.

Pillar Two obligations in Australia during the transition period

Dara Larasati — Thu, 21 Aug 2025 22:37:35 +0000

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 approach for lodgement obligations and penalties during the transition period (fiscal years starting on or before 31 Dec 2026 and ending on or before 30 June 2028).

Australia has introduced a 15% Global and Domestic Minimum Tax (Pillar Two Rules) aligned with the OECD’s Global Anti-Base Erosion (GloBE) Rules under Pillar Two. This targets large multinational enterprise (MNE) groups with consolidated revenues ≥ EUR750 million (AU$1.2 billion or US$820 million) in at least two of the four fiscal years preceding the tested year. The Pillar Two rules apply in Australia from 1 January 2024.

It is noteworthy that effective from 1 January 2025, the Undertaxed Profits Rule may subject an Australian MNE group member to top-up tax related to another group member. This is regardless of whether the former has any ownership interests in the latter. Consequently, auditors might require a Pillar Two analysis for the global group for the 2025 fiscal year.

What are the key lodgement obligations in Australia?

Applicable MNE Groups must lodge the following:

GloBE Information Return (GIR) – OECD- standardised form for calculating tax liability.
Foreign Notification Form (FNF) – Notifies the ATO of foreign GIR lodgement.
Australian IIR/UTPR Tax Return (AIUTR) – Assesses top-up tax under Income Inclusion Rule and Undertaxed Profits Rule.
Australian Domestic Minimum Tax Return (DMTR) – Assesses top-up tax on low-taxed Australian profits.

The AIUTR, DMTR, and FNF are consolidated into the Combined Global and Domestic Minimum Tax Return (CGDMTR). The GIR remains a standalone obligation. The returns are due 18 months after the fiscal year end for the first year and 15 months thereafter. For an MNE group with a fiscal year ending on 31 December 2024, the returns are due on 30 June 2026.

Importantly, the Australian members of an MNE Group must fulfil lodgement obligations in Australia, even if the Parent of the Group is in a country without Pillar Two rules implemented. The Australian entities may nominate one Australian Group Entity, known as the Designated Local Entity (DLE), to lodge the returns on behalf of the Australian entities.

As of the date of this document, Australia has not signed the Multilateral Competent Authority Agreement (MCAA) on the Exchange of GloBE Information (GIR MCAA) under Pillar Two. Until that happens, the GIR must be lodged in Australia with the ATO even if one has been lodged overseas.

Is there a “soft landing” in terms of penalties for taxpayers?

During the transition period, the ATO will adopt a “soft-landing” approach (i.e. penalties remitted) if the MNE group has demonstrated that reasonable measures were taken to comply.

Examples of reasonable measures include:

documented implementation plans and internal policies
system upgrades and gap analyses
proactive engagement with the ATO and external advisors and
timely correction of errors

Furthermore, no penalties should be imposed for isolated or good-faith errors during the transition period. However, gross indifference or failure to take reasonable care may be subject to penalties. Current administration penalties imposed upon Significant Global Entities apply in these circumstances.

How can SW assist?

We can assist with your Pillar Two project implementation by:

implementing SW’s CTS Pillar Two Software for planning, Pillar Two calculations, and lodging GIR and domestic returns
advising how Pillar Two will affect your group
designing a Pillar Two implementation plan tailored to your group’s requirements
identifying and classifying the entities within the group
advising on the application of charging mechanisms
assisting with Transitional CbCR safe harbour calculations

Contributors

Antony Cheung

The post Pillar Two obligations in Australia during the transition period appeared first on SW Accountants & Advisors.

Updates on the Big Beautiful Section 899 & Pillar Two

Dara Larasati — Wed, 02 Jul 2025 03:45:49 +0000

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 Senate has implemented a number of changes to the OBBBA. The revised version of the OBBBA excludes this revenge tax. This change comes after a recommendation from US Treasury Secretary Scott Bessett to remove the tax as part of a deal with the G7 nations (Canada, France, Germany, Italy, Japan, the United Kingdom and the United States). This removal follows widespread concern that the tax was expected to reduce foreign investment into the US costing US jobs.

This version of the OBBBA narrowly passed in the US Senate on 1 July 2025 with Vice President Vance casting the tie breaking vote. Now the OBBBA needs to be reconsidered by Congress prior to the 4 July deadline self-imposed by President Trump.

Arising from the deal with the G7 nations is the newly proposed ‘side-by-side’ solution, whereby US-parented multinational groups would be exempt from the Income Inclusion Rule (IIR) and the Undertaxed Profits Rule (UTPR) under the Organisation for Economic Cooperation and Development’s (OECD) Pillar Two. This is on the basis that the US has its own domestic minimum tax rules.

The removal of proposed Section 899 is great news for Australian entities with investments and/or business interests in the US. This is because there will not be an increase of 5% per annum, for up to an additional 15% beyond the existing reduced treaty rate. Furthermore, no change to the minimum tax of 10% imposed on large corporations per the base erosion and anti-abuse tax (BEAT) regime.

Considering the US parent group exemption is struck between the US and G7 nations (which does not include Australia), the impact on Australia’s implementation of Pillar Two is currently unclear. This is a live issue for multinationals, given the IIR and DMT, and UTPR apply to income years starting 1 January 2024 and 2025, respectively.

G7 statement on global minimum taxes

Following the signing of executive order in January this year by President Trump to ‘defend US tax sovereignty’ and outlining concerns regarding the Pillar Two rules agreed by the OECD/G20 Inclusive Framework (representing over 140 countries), the US and G7 nations came to a joint understanding in their recent summit addressing global minimum tax and tackling tax planning and avoidance. The ‘side-by-side’ arrangement is based on the following principles:

Multinationals with a US parent will be fully exempted from the application of UTPR and IIR (i.e. 15% minimum corporate tax) with regard to domestic and foreign profits

commitment to identifying substantial risks, including base erosion and level-playing concerns

simplifying Pillar Two administration and compliance framework

considering changes to Pillar Two treatment of substance-based non-refundable tax credits aligning with treatment of refundable tax credits.

In return for the US parented group exemption, the proposed section 899 ‘revenge tax’ has been removed from the Senate bill, which was passed overnight.

What this means to Australia (and Pillar Two)

The removal of section 899 will be welcomed by Australian groups that invest and conduct business in the US. This is particularly relevant for superannuation funds taxed at 15% in Australia, where the additional US tax could not be credited and would have directly and immediately impacted investment returns.

This G7 announcement also represents a landmark change to the international tax environment as Pillar Two was developed due to global concerns over the digital economy and base erosion, which worsened in the past two decades.

Noting the Australian domestic minimum tax and IIR, and UTPR affect income years commencing 1 January 2024 and 2025, many practical issues remain unsolved:

As this is a G7 agreement, would it be approved under the broader OECD inclusive framework, representing more than 140 countries?

How would the US entity exclusion play out at the global and Australian domestic level, and will there be roll-back of the legislation, given the intention of these laws is predominantly to target US multinationals?

What is the adverse impact on Australian multinationals since the exclusion provides a structural tax advantage to US multinationals?

Would there be any side deals between Australia and other jurisdictions?

How would the Commissioner (and the ATO) administer the law in the interim while negotiations take place, given a full year has passed since the legislation came into effect?

How SW can help

The ever-evolving nature of US and global tax policies require continued vigilance from Australian entities and their advisors.

SW will monitor and keep you informed as developments happen.

Reach out to your SW contact or our specialist tax contacts listed in this alert for advice.

Contributors

Antony Cheung

Jarrod Newell

The post Updates on the Big Beautiful Section 899 & Pillar Two appeared first on SW Accountants & Advisors.

支柱二常见问答：关于全球最低税的重要见解

Dara Larasati — Tue, 25 Mar 2025 21:13:43 +0000

支柱二实施了一套全球最低税框架，旨在确保跨国企业按公平原则纳税，不论其经营所在地。

本常见问答栏目针对支柱二的实施、对企业的影响以及合规要求这几方面的重要问题提出了看法。无论贵公司想了解实际税率、报告义务还是豁免，都可以在此找到清楚扼要的答案。

Pillar-2-FAQs_zh-3 Download

The post 支柱二常见问答：关于全球最低税的重要见解 appeared first on SW Accountants & Advisors.

Pillar Two FAQs: Key Insights on the Global Minimum Tax

Dara Larasati — Wed, 19 Mar 2025 23:43:42 +0000

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 and concise answers here.

Pillar 2 FAQ Download

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