The OECD’s Global Minimum Tax under Pillar Two is no longer a theoretical exercise for multinational groups. In Australia and across
Asia‑Pacific, it is already reshaping how tax authorities assess transfer pricing outcomes, effective tax rates and the sustainability of
existing operating models.
For in‑scope groups, the real challenge lies in aligning Pillar Two calculations with transfer pricing policies, intragroup financing,
services and IP arrangements, while managing data integrity, governance and audit readiness across jurisdictions. This resource hub brings
together Transfer Pricing Solutions’ practical insights, technical commentary and market experience to help tax and finance leaders
navigate Pillar Two beyond compliance, with a focus on defensible outcomes, risk management and long‑term tax certainty.
Under the OECD Pillar Two global minimum tax framework, in‑scope multinational enterprise (MNE) groups may be subject to a 15% minimum effective tax rate. To administer and monitor compliance, two key reporting obligations are relevant.
To assist taxpayers in complying with new minimum tax requirements, the ATO has released Draft Practical Compliance Guideline PCG 2025/D3, which outlines a practical administrative approach to penalty enforcement during a crucial transition period.
Global Minimum Tax (GMT) is one of the largest tax reformations as part of the initiative under Pillar 2 of the Base Erosion Profit-Shifting (BEPS) 2.0 project.
This article will provide an overview of what global minimum tax is, why it's important, and how it impacts multinational corporations and the global economy.
This article will explore the history of global minimum tax policies, from their origins to the latest developments, including the recent OECD/G20 agreement.
