International taxation – global and domestic minimum tax – primary legislation

4 days left to have your say
Consultation Type
Exposure Draft

Key Documents

In the 2023–24 Budget, the Australian Government announced it would implement key aspects of the OECD/G20 Two‑Pillar Solution to address the tax challenges arising from digitalisation of the economy (the Two‑Pillar Solution).

The exposure draft materials implement these key aspects, delivering on the government’s election commitment to ensure multinationals pay their fair share of tax.

This measure implements a 15 per cent global minimum tax and domestic minimum tax as part of a coordinated approach across approximately 140 Inclusive Framework member jurisdictions in line with the Two‑Pillar Solution.

A previous public consultation was held in relation to the Two‑Pillar Solution in October 2022.

Exposure draft materials

As part of implementing this measure, exposure draft primary legislation, subordinate legislation in the form of Rules and accompanying explanatory materials have been drafted.

This consultation page concerns the exposure draft primary legislation. A separate consultation regarding the exposure draft subordinate legislation material is also available for feedback.

The primary legislation includes:

  • an Imposition Bill which imposes the tax payable under the global and domestic minimum taxes
  • an Assessment Bill which establishes the liability and framework for the global and domestic minimum taxes
  • a Consequential Amendments Bill which contains consequential and miscellaneous provisions necessary for the administration of the global and domestic minimum taxes.

An explanatory memorandum has been prepared covering these three Bills.

A separate discussion paper has also been included to assist stakeholders in providing feedback on interactions between the exposure draft primary legislation and provisions in Australia’s existing income tax law, including:

  • the hybrid mismatch rules
  • controlled foreign company rules
  • foreign income tax offsets.

Have your say

The government is seeking stakeholders’ views on the exposure draft primary legislation, the explanatory memorandum and the separate discussion paper on interactions with provisions in Australia’s existing income tax law. Without intending to limit feedback, the preamble to the explanatory memorandum sets out specific areas the government is seeking views on.

The government is also seeking stakeholder feedback on priority issues that would inform the Australian Taxation Office’s administrative approach and public advice and guidance on this measure. Specifically, the government is interested in feedback on the highest priority issues and the form any public advice and guidance should take.

Submissions on these materials are due 16 April 2024.


You can submit responses to this consultation up until 16 April 2024. Interested parties are invited to comment on this consultation.

While submissions may be lodged electronically or by post, electronic lodgement is preferred. For accessibility reasons, please submit responses sent via email in a Word or RTF format. An additional PDF version may also be submitted.

All information (including name and address details) contained in submissions will be made available to the public on the Treasury website unless you indicate that you would like all or part of your submission to remain in confidence. Automatically generated confidentiality statements in emails do not suffice for this purpose. Respondents who would like part of their submission to remain in confidence should provide this information marked as such in a separate attachment.

Legal requirements, such as those imposed by the Freedom of Information Act 1982, may affect the confidentiality of your submission.

View our submission guidelines for further information.

How To Respond



Address written submissions to:

Pillar Two Unit
Corporate and International Tax Division
Langton Cres
Parkes ACT 2600