ATO Publishes New and Updated Pillar 2 Guidance, Including Guidance for Tax Consolidated Groups
|Approved Changes|Australia

The Australian taxation Office published new Pillar Two global minimum tax guidance on 17 December 2025 in relation to Pillar Two interactions with consolidation. This includes the following:
- Tax consolidated group lodgments for Pillar Two, which covers how Pillar Two lodgment obligations apply to tax consolidated groups;
- Top-up tax for tax consolidated groups, which covers how to calculate and allocate top-up tax for tax consolidated groups; and
- Tax consolidated group reporting for Pill…