Taxation (Multinational—Global and Domestic Minimum Tax) Imposition

Current status

This bill became law on Dec 10th, 2024.

Policy area

Budget, tax & economy

What does this bill do?

Large multinational groups with annual global revenue of at least 750 million euros must now meet a 15 per cent minimum tax rate in Australia and across their global operations.

Why was it introduced?

Large multinationals could still be taxed below 15 per cent, leaving undertaxed profits in Australia and across global groups. The bill imposes Australian top-up taxes so those groups pay the minimum rate here, and requires returns and record-keeping to enforce it.

Broader context

Australia already had multinational tax avoidance rules, but large cross-border groups could still end up paying effective tax rates below 15 per cent by shifting profits across jurisdictions. After Australia backed the OECDThe international body behind the global minimum tax rules that Australia says it is now implementing.-G20The group of the world's major economies that worked with the OECD on the minimum tax deal mentioned on the page. minimum-tax approach and Labor took it to the 2022 election, this bill formed part of a 2024 package that created Australian top-up taxes for those undertaxed profits, and after Parliament passed it the new regime began applying from 1 January 2025 for its final backstop tax.

Key criticism

Little direct criticism of the bill itself was recorded; the main reservation was that it was either only a partial fix to multinational tax avoidance or was being advanced alongside wider tax settings critics said were hurting households and business. Those concerns were limited and mostly conditional, with the Coalition saying it would not oppose the bill and the Greens supporting it in the House while arguing broader reform was still needed.

Who supported it?

Hon Dr Andrew Leigh MP introduced this bill. It passed on the voices.

Introduced in House 04 July 2024
Passed House 22 Aug 2024
Passed Senate 26 Nov 2024
Became law 10 Dec 2024

Did it become law?

Yes

Became law 10 Dec 2024

Final passage

Passed without a counted vote

Members called out ‘aye’ or ‘no’ — no individual votes were recorded.

Passage speed

159 days

From introduction to the latest recorded parliamentary step

Official record

View on APH

Parliament of Australia bill page

What does this bill do?

  1. Large multinational groups with annual global revenue of at least 750 million euros must now meet a 15 per cent minimum tax rate in Australia and across their global operations.

  2. Australia can now charge three top-up taxes so undertaxed profits are taxed here, including a domestic top-up tax and two taxes linked to low-taxed profits in multinational groups.

  3. Australian domestic top-up tax and the parent-entity top-up tax apply to fiscal years starting on or after 1 January 2024, while the backstop top-up tax starts from fiscal years beginning on or after 1 January 2025.

  4. Affected multinational groups must lodge electronic minimum-tax returns, generally within 15 months after each fiscal year, or 18 months for the first year the rules apply.

  5. Multinational groups in scope must keep records for at least 8 years to show they complied with the new minimum tax rules, and failing to do so is an offence.

Show source excerpts
  1. The Bills implement a 15 per cent global minimum tax and Australian domestic minimum tax on certain MNEs with annual global revenue of at least EUR 750 million.
    Taxation (Multinational—Global and Domestic Minimum Tax) Imposition explanatory memorandum
  2. The Imposition Bill imposes top-up tax, namely Australian DMT tax, Australian IIR tax and Australian UTPR tax.
    Taxation (Multinational—Global and Domestic Minimum Tax) Imposition explanatory memorandum
  3. Australian DMT tax and Australian IIR tax apply for Fiscal Years beginning on or after 1 January 2024. Australian UTPR tax applies for Fiscal Years beginning on or after 1 January 2025.
    Taxation (Multinational—Global and Domestic Minimum Tax) Imposition explanatory memorandum
  4. The due date for lodgment of the returns is harmonised. The Australian IIR/UTPR Tax Return and the Australian DMT Tax Return must be lodged within the time that is specified for the lodgment of the GloBE Information Return. This is consistent with the GloBE Rules, which stipulate lodgment to be within 15 months after the end of every Fiscal Year. However, an exception applies for the first Fiscal Year in which a jurisdiction’s domestic law implementation of the GloBE Rules is applied by an MNE Group, where the return must be given within 18 months after the end of the Fiscal Year.[Schedule 1, item 35, subsections 127-60(1) and (2) in Schedule 1 to the TAA]
    Taxation (Multinational—Global and Domestic Minimum Tax) Imposition explanatory memorandum
  5. Records must be kept until the end of 8 years after those records were prepared or obtained, or the completion of the transactions or acts to which those records relate, whichever is the later. The length of this record keeping retention period is necessary given the extended period of time the treatment and calculations under the Assessment Bill operate, as well as the relatively long timeframes for lodgment and exchange of the GloBE Information Return. [Schedule 1, item 60, subsection 382-20(1)(b) in Schedule 1 to the TAA]
    Taxation (Multinational—Global and Domestic Minimum Tax) Imposition explanatory memorandum

Broader context for this bill

Australia already had multinational tax avoidance rules, but large cross-border groups could still end up paying effective tax rates below 15 per cent by shifting profits across jurisdictions. After Australia backed the OECDThe international body behind the global minimum tax rules that Australia says it is now implementing.-G20The group of the world's major economies that worked with the OECD on the minimum tax deal mentioned on the page. minimum-tax approach and Labor took it to the 2022 election, this bill formed part of a 2024 package that created Australian top-up taxes for those undertaxed profits, and after Parliament passed it the new regime began applying from 1 January 2025 for its final backstop tax.

  1. 2014

    Australia backs OECDThe international body behind the global minimum tax rules that Australia says it is now implementing. work on multinational tax avoidance at the G20The group of the world's major economies that worked with the OECD on the minimum tax deal mentioned on the page.

    Parliamentary debate linked the bill to Australia’s earlier support for coordinated international tax rules aimed at limiting profit shifting by large multinationals.

    Hansard ↗
  2. 2022

    Labor takes the OECDThe international body behind the global minimum tax rules that Australia says it is now implementing.-G20The group of the world's major economies that worked with the OECD on the minimum tax deal mentioned on the page. minimum-tax plan to the election

    Government speakers said the 2024 legislation delivered a 2022 election commitment to support the two-pillar global tax deal for very large multinational groups.

    Hansard ↗
  3. 04 July 2024

    Government introduces the 15 per cent top-up tax package

    The bill was introduced as part of a three-bill package to impose global and domestic minimum taxes on multinational groups with annual global revenue of at least 750 million euros.

    Hansard ↗
  4. 26 Nov 2024

    Parliament passes the bill

    Both houses passed the bill, clearing the way for Australia to charge top-up tax where multinational profits were taxed below the new minimum rate.

    Parliamentary timeline ↗
  5. 10 Dec 2024

    Royal AssentThe final step that turns the bill into an Act, which the page says happened before the new tax start dates. makes the minimum-tax law official

    Royal AssentThe final step that turns the bill into an Act, which the page says happened before the new tax start dates. turned the bill into an Act ahead of the staged start dates for Australia’s domestic, parent-entity and backstop top-up taxes.

    Parliamentary timeline ↗
  6. 01 Jan 2025

    Backstop top-up tax begins applying to later fiscal years

    From fiscal years starting on or after 1 January 2025, Australia’s backstop tax joined the earlier-starting minimum-tax rules as the final part of the regime.

    Australian Parliament House ↗

How did it move through Parliament?

House Senate
Introduced 04 July 2024

The bill was formally presented to the chamber and read a first time, which starts its parliamentary journey.

Introduced and read a first time

Second reading opened 04 July 2024

A minister or sponsoring member moved the second reading, opening the main debate on the bill's purpose and principles.

Second reading moved

Economics Legislation Committee; Committee report (14/08/2024) review 04 July 2024

Referred to Committee (04/07/2024): Senate Economics Legislation Committee; Committee report (14/08/2024)

Referred to committee

APH bill page notes
Second reading debate 13 Aug 2024

The bill reached this recorded parliamentary step.

Sent to Federation Chamber for debate 20 Aug 2024

The bill reached this recorded parliamentary step.

Referred to Federation Chamber

Federation Chamber debate 20 Aug 2024

The bill reached this recorded parliamentary step.

Second reading debate

Second reading debate 21 Aug 2024

The bill reached this recorded parliamentary step.

House second reading agreed 21 Aug 2024

The chamber agreed to the bill at second reading, meaning it accepted the bill in principle and allowed it to continue.

Second reading agreed to

Returned from Federation Chamber 22 Aug 2024

The bill reached this recorded parliamentary step.

Reported from Federation Chamber

House third reading agreed 22 Aug 2024

The chamber agreed to the bill at third reading, which completed passage through that chamber.

Third reading agreed to

Introduced 22 Aug 2024

The bill was formally presented to the chamber and read a first time, which starts its parliamentary journey.

Introduced and read a first time

Second reading opened 22 Aug 2024

A minister or sponsoring member moved the second reading, opening the main debate on the bill's purpose and principles.

Second reading moved

Second reading debate 10 Sept 2024

The bill reached this recorded parliamentary step.

Second reading debate 26 Nov 2024

The bill reached this recorded parliamentary step.

Senate second reading agreed 26 Nov 2024

The chamber agreed to the bill at second reading, meaning it accepted the bill in principle and allowed it to continue.

Second reading agreed to

Committee of the Whole debate 26 Nov 2024

The bill reached this recorded parliamentary step.

Senate third reading agreed 26 Nov 2024

The chamber agreed to the bill at third reading, which completed passage through that chamber.

Third reading agreed to

Passed both houses 26 Nov 2024

Both houses passed the bill in the same form, completing parliamentary passage.

Finally passed both Houses

Assent 10 Dec 2024

The Governor-General gave Royal AssentThe final step that turns the bill into an Act, which the page says happened before the new tax start dates., turning the bill into an Act.

The main case against this bill

Little direct criticism of the bill itself was recorded; the main reservation was that it was either only a partial fix to multinational tax avoidance or was being advanced alongside wider tax settings critics said were hurting households and business. Those concerns were limited and mostly conditional, with the Coalition saying it would not oppose the bill and the Greens supporting it in the House while arguing broader reform was still needed.

No party represented in the debate opposed the bill itself, and criticism was mostly broader or conditional.

Recorded votes

How the bill itself passed

The bill passed both chambers on the voices, so there is no list of individual Aye and No votes for final passage.

Passed

House passed the bill

House agreed to the bill's third reading on the voices, so there is no list of individual Aye and No votes for final passage in that chamber.

22 Aug 2024

Passed on the voices

In a voice vote, members call out Aye or No and the presiding officer judges which side has it. Individual names are only recorded if a formal division is called.

Passed

Senate passed the bill

Senate agreed to the bill's third reading on the voices, so there is no list of individual Aye and No votes for final passage in that chamber.

26 Nov 2024

Passed on the voices

In a voice vote, members call out Aye or No and the presiding officer judges which side has it. Individual names are only recorded if a formal division is called.

Who spoke, and what they said

Start here — lead voices

Sponsor speech Supports

Andrew Leigh

Australian Labor Party • MP 04 July 2024

Leigh supports the bill as part of a package that will create a 15 per cent global and domestic minimum tax for large multinationals operating in Australia.

Read in Hansard ↗
Lead supporting voice Supports

Simon Kennedy

Liberal Party • MP 20 Aug 2024

Kennedy says the opposition supports the bill and welcomes its multinational tax measures, but argues Labor has broken its tax promises and is not doing enough for small businesses and ordinary Australians.

Read in Hansard ↗
Lead non-major voice Supports

Allegra Spender

Independent • MP 21 Aug 2024

Spender supports the bill and says it will help align global minimum tax rates so multinationals pay their fair share in Australia.

Read in Hansard ↗
Lead voice Supports

Tim Ayres

Australian Labor Party • Senator 22 Aug 2024

Ayres supports the bill and says it is part of a wider package to impose a 15 per cent global and domestic minimum tax on large multinationals.

Read in Hansard ↗

All speeches by bloc

Labor

10 speakers · 11 contributions · 10 support

  1. Peter Khalil Peter Khalil supports the bill and says it will help stop multinational profit shifting by imposing a 15 per cent global and domestic minimum tax.
    “To support the government's effort to crack down on multinationals tax avoidance, the government is introducing the Taxation (Multinational—Global and Domestic Minimum Tax) Bill. This legislation delivers on the government's election commitment to ensure multinationals pay their fair share of tax by implementing a 15 per cent global and domestic minimum tax rate. It forms part of a coordinated approach across more than 130 countries to implement the OECD-G20 two-pillar solution, a 2021 international agreement to address the tax challenges that have been coupled with the rise of the digital economy. This bill also responds to the problem of large multinational corporations seeking to reduce tax by shifting profits from Australia to low-tax or no-tax jurisdictions such as the Cayman Islands, pretending that their headquarters are there, even though they're making the profits here. This effectively erodes Australia's tax base. It reduces the money that can be invested into the vital services that Australians rely upon every day.”

    Australian Labor Party • MP • 21 Aug 2024

    Read the full speech in Hansard ↗
  2. Alicia Payne Alicia Payne supports the bill and says it will help multinational companies pay a fairer share of tax by putting Australia into the first group of countries implementing the global and domestic 15 per cent minimum tax.
    “Australia has long been a champion of the global 15 per cent minimum tax, and we are now in the first group of nations to implement the global minimum tax and domestic minimum tax of 15 per cent. From this year, this tax will apply to multinational enterprises with an annual global revenue of at least 750 million euros, which is approximately A$1.2 billion or greater. The global minimum tax will ensure large multinational enterprises pay a minimum level of tax on income arising in each jurisdiction where they operate. This will support global momentum towards a fairer international tax system by putting a floor on tax competition and levelling the playing field between large multinational enterprises and Australian businesses.”

    Australian Labor Party • MP • 20 Aug 2024

    Read the full speech in Hansard ↗
  3. Tania Lawrence Lawrence supports the bill, saying it will help stop multinational tax avoidance, create a fairer playing field for Australian businesses, and strengthen the revenue needed for public services.
    “This is good legislation, and it evidences Australia's commitment to a better, fairer and more equal economic global order. Ernst & Young described the introduction of this regime as a significant shift in global taxation. Australia has been a firm champion of the global 15 per cent minimum tax rate on multinationals. By enacting this legislation now, we will be among a strong group of first movers, the actions of which will bring other nations more quickly to agreement and cooperation. I support the bill and look forward to seeing the intent of this legislation supported across this parliament and across the world.”

    Australian Labor Party • MP • 20 Aug 2024

    Read the full speech in Hansard ↗
  4. Daniel Mulino Mulino supports the bill, saying it will let Australia apply a 15 per cent global and domestic minimum tax on large multinationals and curb profit shifting.
    “I'm pleased to rise today to speak in support of this bill, the Taxation (Multinational—Global and Domestic Minimum Tax) Bill 2024. I would note from the outset that is one of a package of three bills which together enact a 15 per cent global minimum tax and domestic minimum tax for multinational enterprises operating in Australia with an annual global revenue of 750 million euros or greater, which is approximately A$1.2 billion. There are other bills as part of this package which relate to capital thinning and greater transparency across jurisdictions.”

    Australian Labor Party • MP • 20 Aug 2024

    Read the full speech in Hansard ↗
  5. Graham Perrett Graham Perrett supports the bill and says it is a necessary reform to make large multinationals pay tax in Australia and to strengthen tax transparency.
    “The Albanese Labor government is committed to ensuring that big multinational corporations that make a profit in Australia pay tax in Australia. This was an election commitment, and I'm happy to speak in support of this necessary reform, the Taxation (Multinational—Global and Domestic Minimum Tax) Bill 2024. It builds on the substantial reforms already implemented by Labor regarding the taxation of large multinational corporations.”

    Australian Labor Party • MP • 20 Aug 2024

    Read the full speech in Hansard ↗
  6. Sam Rae Sam Rae supports the bill and says it will help Australia collect a minimum tax from large multinationals and protect revenue from undertaxed profits.
    “In addition to a global minimum tax, this legislation—the Taxation (Multinational—Global and Domestic Minimum Tax) Bill 2024 and related bills—also implements a domestic minimum tax which will give Australia additional taxing rights on the low-taxed Australian income of large multinational groups. This is a critical safeguard to ensure that Australia collects revenue from local undertaxed profits.”

    Australian Labor Party • MP • 21 Aug 2024

    Read the full speech in Hansard ↗
  7. Helen Polley Helen Polley says Labor supports the bill and urges the crossbench to back it because it would make multinational companies pay their fair share of tax and strengthen fairness, transparency and integrity in the tax system.
    “Tonight, I would like to urge those sitting on the crossbench to support this crucial piece of legislation to ensure that multinational corporations both globally and domestically are taxed fairly, because every Australian taxpayer needs to be treated fairly.”

    Australian Labor Party • Senator • 10 Sept 2024

    Read the full speech in Hansard ↗
  8. Jess Walsh Walsh strongly supports the bill, saying it is a sensible next step in Labor's multinational tax reform agenda and will help ensure large companies pay at least a 15 per cent tax rate.
    “These bills, the Taxation (Multinational—Global and Domestic Minimum Tax) Bill 2024 and related bills, are just the next step in our government's agenda to deliver on our commitments. They legislate the powers necessary to allocate top-up taxes where companies have not paid at least a 15 per cent rate of corporate tax. That can be in Australia or in another jurisdiction. In effect, this sets a global floor on corporate taxes, directly addressing the race to the bottom of corporate tax, ensuring that when companies may be doing the wrong thing, when they may be shifting profits to avoid paying their fair share of tax, there is a multilateral approach to correcting that.”

    Australian Labor Party • Senator • 10 Sept 2024

    Read the full speech in Hansard ↗

Coalition

8 speakers · 7 support · 1 mixed

  1. Anne Webster Webster supports the bill as part of the coalition's push to curb multinational tax avoidance, saying Australia needs to stand up to tech giants and make them pay more of their fair share.
    “In conclusion, this bill builds on the coalition's world leadership of acting in the Australian national interest, and I believe the current government must do more. The tax-avoiding multinationals do not have Australia's best interests at heart, and we need the federal government to stand up to them.”

    National Party • MP • 21 Aug 2024

    Read the full speech in Hansard ↗
  2. Angus Taylor Taylor says the opposition will not oppose the bill and supports the multinational tax changes in principle, but only subject to the amendments he has moved.
    “Changes to these multinational tax arrangements—and we do in principle, subject to the amendments that I have just moved, support them—do not make up for Labor's attacks on aspirational Australians.”

    Liberal Party • MP • 13 Aug 2024

    Read the full speech in Hansard ↗
  3. Michael McCormack McCormack says the coalition supports the bill because measures against multinational tax avoidance are overdue.
    “This taxation measure is something that the coalition believes is overdue. Labor needs to stop whacking everybody with its high taxes, but the bill is, as I say, something that very much needs to be looked at.”

    National Party • MP • 21 Aug 2024

    Read the full speech in Hansard ↗
  4. Keith Wolahan Wolahan says the coalition will support the bill because it targets multinational tax avoidance, but he argues that support should not excuse the government’s broken promises and higher domestic taxes.
    “These are important bills. They have our support, but that support should not be given by the coalition in a way that doesn't acknowledge the promises that have been broken and the serious work that has to be done on out-of-control spending by this government which is impacting the task of bringing inflation down now and doing nothing to fix that horror story that we see in the Intergenerational report of 40 years from now. We must all, as a matter of urgency, turn our mind to that.”

    Liberal Party • MP • 20 Aug 2024

    Read the full speech in Hansard ↗
  5. Dan Tehan Tehan says the opposition supports the bill as part of the work on multinational tax and the OECDThe international body behind the global minimum tax rules that Australia says it is now implementing. two-pillar deal, because he wants multinationals to pay their fair share.
    “As we've seen with multinationals over a period of time, there have been real concerns about whether we are getting multinationals paying their fair share of tax. That's why, when the coalition were in government, we started a process of making sure that multinationals would be taxed fairly. As the Deputy Speaker and everyone in this chamber knows, that was incredibly important work. What we're seeing from the government is a continuation of that process, including the OECD two-pillar solution to multinational tax avoidance. We obviously support that work, because we want to make sure that multinationals are paying their fair share. As I illustrated in the example before, if we're not getting everyone to pay their fair share, then pressure comes onto government to provide the services that they need.”

    Liberal Party • MP • 21 Aug 2024

    Read the full speech in Hansard ↗
  6. Jane Hume Hume says the coalition will not oppose the bill and supports continuing the multinational tax avoidance reforms, because they back the OECDThe international body behind the global minimum tax rules that Australia says it is now implementing. process and the goal of fairer tax rules.
    “While the coalition will not oppose this legislation, we will not apologise for holding the government to account for their broken promises on tax and their failure to take meaningful action on productivity and indeed potentially making the problem even worse.”

    Liberal Party • Senator • 26 Nov 2024

    Read the full speech in Hansard ↗
  7. Jonathon Duniam Duniam says the coalition will not oppose the bill and supports the effort to continue international work on multinational tax avoidance.
    “Australians deserve a government that is focused on the challenges they face today. And while the coalition will not oppose this legislation, we will not apologise for holding this government to account for their broken promises on tax, their failure to take meaningful action on productivity, and their lack of focus on fighting inflation. We need a government that prioritises the economic wellbeing of all Australians and takes real steps to address the cost-of-living crisis, improve productivity and, importantly, restore confidence in our economy.”

    Liberal Party • Senator • 10 Sept 2024

    Read the full speech in Hansard ↗

Greens

2 speakers · 2 support

  1. Nick McKim Nick McKim supports the bill, arguing that this bill implements internationally agreed rules to ensure that multinational corporations with an annual global revenue of A$1.2 billion or greater are subject to a global minimum tax rate of 15 per cent.
    “This bill implements internationally agreed rules to ensure that multinational corporations with an annual global revenue of A$1.”

    Australian Greens • Senator • 10 Sept 2024

    Read the full speech in Hansard ↗
  2. Adam Bandt Bandt says the Greens will support the bill through the House, while reserving their position in the Senate.
    “The Greens will support this bill, the Taxation (Multinational—Global and Domestic Minimum Tax) Bill 2024, through the House, but we will reserve our position in the Senate.”

    Australian Greens • MP • 20 Aug 2024

    Read the full speech in Hansard ↗

Minor parties and independents

2 speakers · 2 support

  1. Rebekha Sharkie Sharkie supports the bill because she sees it as a fair reform that helps make multinational tax settings more consistent and may improve investment and jobs in Australia.
    “Equalising or at least bringing business costs closer, irrespective of where the business is domiciled, can't come at a more important time. Across Australia, corporate insolvencies are surging, as inflation, cost of living and energy prices are taking effect. In the last 12 months, insolvencies exceeded 10,000 for the first time since 2013. The trend is alarming. For the first nine months of the financial year, insolvencies rose by 36.2 per cent on the previous corresponding period. Monthly filings reached 1,137 insolvencies in March 2024. That was a record until May, when 1,249 new cases were initiated. While most of these companies are local, the benefit of a globally [inaudible] tax system will result in more companies investing or relocating their operations to Australia, with flow-on effects to the local economy. It is also reasonable to conclude that some of the $976 billion—nearly a trillion—in outbound foreign direct investment emanating from Australian businesses in 2022 would be redirected into Australia, creating local jobs and local opportunities. This bill provides improved fairness across the global economy. It is an appropriate reform and one that I certainly support. I thank the House.”

    Centre Alliance • MP • 20 Aug 2024

    Read the full speech in Hansard ↗

Full record

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