ATO Publishes Guidance on Pillar 2 Treatment of Tax Consolidated Group Restructures and Transition Rules

The Australian Taxation Office (ATO) has published guidance on Tax consolidated group restructures and transition rules, which explains how Australia’s Pillar 2 minimum tax rules treat acquisitions, restructures, and other ownership or asset transfers involving tax consolidated groups. In particular, the guidance covers the following:

• Restructure rules and transition rules for tax consolidated groups
• Section 9-5: Baseline transition rule
• Subsection 9-5(3): Baseline integrity rule
• Section 9-…