Australia Tax Agency Issues Practical Compliance Guideline on Transitional Pillar 2 Filing Penalty Approach

The Australian Taxation Office Nov. 26 issued Practical Compliance Guideline No. PCG 2025/4, on a transitional approach to domestic filing penalties related to 15 percent global minimum taxation under Pillar Two. Topics covered include: 1) the Tax Agency’s adoption of the OECD’s transitional penalty approach, under which no penalties apply related to filing a Global Anti-Base Erosion (GloBE) Information Return (GIR) if reasonable measures were taken to correctly apply the GloBE Rules; 2) information on what constitutes reasonable measures; and 3) procedures for a multinational enterprise (MNE) group’s designated local entity to request filing deferrals, or suspension of filing enforcement ...