The GIR must be prepared by in‑scope MNE Groups with:

• Consolidated revenue of €750 million or more in at least two of the four preceding fiscal years

The GIR is typically filed by:

• The Ultimate Parent Entity (UPE), or
• A Designated Filing Entity (DFE) acting for the group

Only one GIR is lodged globally for the group.

The CGDMTR must be lodged by Australian constituent entities that are members of an in‑scope MNE Group.

Each Australian entity has a legal obligation, but this is usually satisfied by appointing a Designated Local Entity (DLE) to lodge one CGDMTR on behalf of all Australian entities.

If an MNE group does not nominate a DLE or only nominates one for the GIR and not the CGDMTR (which includes the AIUTR and DMTR), each individual entity with those lodgment obligations must lodge its own return or notice.

The GIR and CGDMTR are required to be lodged:

• 18 months after the end of the first fiscal year

The extended lodgment period applies only to MNE groups in scope from the first applicable fiscal year and does not apply to MNE groups that become in scope in a later fiscal year, and

• 15 months after the end of the subsequent fiscal years.

Example:

For a group with a 31 December 2024 year‑end, first filings are due by 30 June 2026.

Even if no Australian top‑up tax is payable, a CGDMTR must still be lodged (nil return).

The GIR contains Pillar Two data for all jurisdictions, including:

•                Group structure and entity listings
•                GloBE income and losses
•                Covered taxes and deferred taxes
•                Effective Tax Rate (ETR) by jurisdiction
•                Top‑up tax computations
•                Application of safe harbours and exclusions

The GIR follows the OECD GloBE rules and is highly data‑intensive.

The CGDMTR includes Australia‑specific information, typically organised into the following sections:

Group and entity identification

• MNE group details
• Australian constituent entities
• Identification of the Designated Local Entity (DLE)

Foreign Lodgment Notification (GIR notification)

• Confirmation of whether the GIR is lodged overseas
• Jurisdiction of filing
• Identity of the UPE or DFE lodging the GIR

Australian Domestic Minimum Tax Return

• Australian GloBE income
• Adjusted covered taxes
• Australian ETR
• Domestic top‑up tax payable (if any)

Australian IIR / UTPR section (if applicable)

• Allocation of foreign low‑taxed profits to Australia
• Calculation of any Australian top‑up tax under IIR or UTPR

Declarations

• Accuracy and completeness confirmations
• Statement that Pillar Two records are maintained

To comply with both GIR and CGDMTR requirements, companies should:

1. Confirm Pillar Two scope

• Confirm whether the group breaches the €750m threshold
• Identify all Australian constituent entities
• Assess any exclusions or safe harbour eligibility

 
2. Build Pillar Two data capability

• Extract data from consolidation and local ledgers
• Recompute income and taxes under GloBE rules (not local tax rules)
• Track deferred tax attributes correctly
• Ensure GIR and CGDMTR figures are consistent

 
3. Appoint filing entities
               Nominate:

• DFE for GIR (global level)
• DLE for CGDMTR (Australia)
• Ensure internal authorisations and governance are in place

 
4. Prepare for ATO lodgment

• Set up access to ATO Online services
• Configure myID and Access Manager permissions
• Decide whether to lodge manually or via tax software (especially for large groups)

5. Align GIR and CGDMTR processes

• Ensure GIR data flows into CGDMTR correctly
• Document assumptions, elections, and calculations
• Prepare for ATO review or audit enquiries