Australia Treasury Seeks Comments on Draft Amendments to Global Minimum Tax Rules Under Pillar 2

The Australian Treasury Oct. 27 opened a consultation on draft amendments to the global minimum tax rules for multinational enterprise (MNE) groups under OECD Pillar Two. The draft amendments include measures to: 1) specify that the rules for constituent entities of an MNE don’t apply to constituent entities subject to the undertaxed profits rule (UTPR) top-up tax; 2) add provisions regarding adjustments for excluded gains or losses and related rules on qualified flow-through tax benefits; and 3) clarify the investment entity transparency election for regulated mutual insurance companies. The amendments would enter into force the day after registration, and would ...