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

The Australian Treasury Feb. 16 opened a consultation on draft amendments to global minimum tax rules for multinational enterprise (MNE) groups under OECD Pillar Two. The draft amendments include measures to: 1) limit the domestic top-up tax (DTT) for stateless constituent entities to pass-through entities created in Australia, and stateless permanent establishments (PEs) operating in Australia; 2) allocate DTT amounts from tax consolidated group subsidiaries to ultimate parent entities in accordance with Australian tax law; 3) impose covered taxes on hybrid and reverse hybrid entities consistently with the Global Anti-Base Erosion (GloBE) income allocation rules; 4) clarify the DTT’s interaction ...