This bill became law on Dec 10th, 2024.
Budget, tax & economy
Large multinational groups in Australia must lodge a global information returnA group-level tax report that tells the ATO how the multinational group is structured and how the minimum tax rules apply to it. and Australian minimum tax returns with the Australian Taxation OfficeThe tax office that collects the filings and payments this bill requires from large multinational groups., even where the tax amount is nil.
Australia’s new global and domestic minimum tax created practical gaps about how multinationals report, pay, and treat those taxes in the existing tax system. This bill sets the filing and payment rules and clarifies deductions, franking creditsTax credits attached to company dividends, which this bill allows to arise when an Australian company pays the domestic minimum top-up tax., and foreign tax offsets for the new top-up taxes.
After Labor committed at the 2022 election to the OECD-G20 two-pillar tax dealThe international agreement that led Australia to adopt the global minimum tax package described on this page., the government moved in 2024 to impose a 15 per cent global minimum taxThe 15 per cent floor for large multinationals that this bill helps administer in Australia. and a domestic minimum top-up taxThe Australian tax that tops up tax on profits booked in Australia to the minimum rate. on large multinationals, closing gaps that let profits be taxed below that floor. Because those new taxes did not fit neatly into Australia’s existing tax administration and imputation rules, this consequential bill set the return, payment, deduction, franking and foreign tax offset rules needed to make the regime work, and it became law in December 2024.
The main reservation was not that this bill went too far, but that it did not go far enough on its own to stop large multinationals avoiding tax or to fix wider problems in the tax system. That view came from some supporters including the Greens and crossbenchers, while no party represented in the debate opposed the bill itself.
Hon Dr Andrew Leigh MP introduced this bill. It passed on the voices.
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
Meaning
Large multinational groups in Australia must lodge a global information returnA group-level tax report that tells the ATO how the multinational group is structured and how the minimum tax rules apply to it. and Australian minimum tax returns with the Australian Taxation OfficeThe tax office that collects the filings and payments this bill requires from large multinational groups., even where the tax amount is nil.
Australian minimum top-up taxThe extra tax charged in Australia when a local group is taxed below the 15 per cent minimum rate. is usually due 15 months after the end of the group’s financial year, giving affected multinationals a set payment deadline.
Companies cannot claim an income tax deduction for paying Australia’s global minimum taxThe 15 per cent floor for large multinationals that this bill helps administer in Australia. or Australia’s domestic minimum top-up taxThe Australian tax that tops up tax on profits booked in Australia to the minimum rate..
Australian companies can get franking creditsTax credits attached to company dividends, which this bill allows to arise when an Australian company pays the domestic minimum top-up tax. when they pay Australia’s domestic minimum top-up taxThe Australian tax that tops up tax on profits booked in Australia to the minimum rate., which helps that tax flow through the dividend imputation systemThe system that passes company tax credits through to shareholders when dividends are paid..
Australia will not give a foreign income tax offsetThe credit mechanism Australia uses to avoid double taxation, which this bill says will not apply to certain foreign top-up taxes. for foreign income inclusion ruleA rule that lets a parent-country tax authority collect top-up tax from the parent entity first. or undertaxed profits ruleA backup rule that lets other countries collect top-up tax if the income inclusion rule does not fully do it. top-up taxes paid overseas.
Certain Group Entities of an Applicable MNE Group must give the Commissioner a GloBE Information Return, Australian IIR/UTPR tax return and Australian DMT tax return.Treasury Laws Amendment (Multinational—Global and Domestic Minimum Tax) (Consequential) as-passed bill text
An amount of Australian IIR/UTPR tax and Australian DMT tax for a Fiscal Year is usually due and payable on the last day of the 15th month after the end of the Fiscal Year.Treasury Laws Amendment (Multinational—Global and Domestic Minimum Tax) (Consequential) as-passed bill text
You cannot deduct under this Act an amount of *Australian IIR/UTPR tax or *Australian DMT tax that you pay.Treasury Laws Amendment (Multinational—Global and Domestic Minimum Tax) (Consequential) as-passed bill text
As Australian DMT tax is an Australian domestic tax, the payment of Australian DMT tax will give rise to franking credits in the entity’s franking account. An entity pays Australian DMT tax, for the purposes of the imputation regime, if the entity has a liability to pay the tax and either makes a payment of that tax (in whole or part) or a credit or RBA surplus is applied to discharge or reduce that liability.[Schedule 1, items 10 to 12, item 9 of the table in subsection 205-15(1), the heading to section 205-20 and subsection 205-20(3B) of the ITAA 1997]Treasury Laws Amendment (Multinational—Global and Domestic Minimum Tax) (Consequential) explanatory memorandum
(6) An amount you paid of any of the following does not count towards the *tax offset for the year:Treasury Laws Amendment (Multinational—Global and Domestic Minimum Tax) (Consequential) as-passed bill text
Context
After Labor committed at the 2022 election to the OECD-G20 two-pillar tax dealThe international agreement that led Australia to adopt the global minimum tax package described on this page., the government moved in 2024 to impose a 15 per cent global minimum taxThe 15 per cent floor for large multinationals that this bill helps administer in Australia. and a domestic minimum top-up taxThe Australian tax that tops up tax on profits booked in Australia to the minimum rate. on large multinationals, closing gaps that let profits be taxed below that floor. Because those new taxes did not fit neatly into Australia’s existing tax administration and imputation rules, this consequential bill set the return, payment, deduction, franking and foreign tax offset rules needed to make the regime work, and it became law in December 2024.
Labor commits to the OECD-G20 two-pillar tax dealThe international agreement that led Australia to adopt the global minimum tax package described on this page.
Government speakers said the 2024 package implemented Labor’s 2022 election commitment to support the multinational minimum tax plan developed through the OECD-G20 process.
Hansard ↗Government introduces a 15 per cent minimum tax package for large multinationals
The minister said a package of three bills would impose a 15 per cent global minimum taxThe 15 per cent floor for large multinationals that this bill helps administer in Australia. and domestic minimum tax on multinational groups with annual global revenue of at least 750 million euros.
Hansard ↗Consequential bill sets filing, payment and tax treatment rules
The second reading speech said this bill made the consequential amendments needed so the new minimum taxes would be administered properly and interact with existing Australian tax laws.
Hansard ↗Parliament passes the bill
Both houses agreed on the same text after the House dealt with Senate amendments, completing the bill’s parliamentary passage.
Parliamentary timeline ↗Royal AssentThe final step that turns a passed bill into an Act and makes the changes law. makes the changes law
Royal AssentThe final step that turns a passed bill into an Act and makes the changes law. completed the legislative package that lets Australia’s new minimum tax regime operate through the existing tax system.
Parliamentary timeline ↗Legislative route
The bill was formally presented to the chamber and read a first time, which starts its parliamentary journey.
Introduced and read a first time
A minister or sponsoring member moved the second reading, opening the main debate on the bill's purpose and principles.
Second reading moved
Referred to Committee (04/07/2024): Senate Economics Legislation Committee; Committee report (14/08/2024)
Referred to committee
APH bill page notesThe bill reached this recorded parliamentary step.
The bill reached this recorded parliamentary step.
Referred to Federation Chamber
The bill reached this recorded parliamentary step.
Second reading debate
The bill reached this recorded parliamentary step.
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
The bill reached this recorded parliamentary step.
Reported from Federation Chamber
The chamber agreed to the bill at third reading, which completed passage through that chamber. Later message exchanges with the other chamber were still recorded afterwards.
Third reading agreed to
The bill was formally presented to the chamber and read a first time, which starts its parliamentary journey.
Introduced and read a first time
A minister or sponsoring member moved the second reading, opening the main debate on the bill's purpose and principles.
Second reading moved
The bill reached this recorded parliamentary step.
The bill reached this recorded parliamentary step.
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
The chamber considered amendments before the bill moved to the next stage.
Committee of the Whole debate
The chamber agreed to the bill at third reading, which completed passage through that chamber.
Third reading agreed to
The House dealt with Senate amendments or requests so both chambers could settle the bill in the same form.
Consideration of Senate message
Both houses passed the bill in the same form, completing parliamentary passage.
Finally passed both Houses
The Governor-General gave Royal AssentThe final step that turns a passed bill into an Act and makes the changes law., turning the bill into an Act.
Key criticism
The main reservation was not that this bill went too far, but that it did not go far enough on its own to stop large multinationals avoiding tax or to fix wider problems in the tax system. That view came from some supporters including the Greens and crossbenchers, while no party represented in the debate opposed the bill itself.
No significant public case against the bill itself is recorded so far.
Too limited on its own
Some supporters argued the bill is only a partial step and will not by itself stop big multinationals, including fossil fuel and tech companies, from minimising tax through wider gaps in the system. Their concern was about the bill's limited scope rather than opposition to the minimum tax measures themselves.
Further sources
Votes
The bill passed both chambers on the voices, so there is no list of individual Aye and No votes for final passage.
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.
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.
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.
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.
Amendments grouped by chamber. Where APH reports aggregate counts, the package card summarizes the matching public amendment sheets by source theme.
House
The House agreed to the amendments made by the Senate, so the bill could pass both chambers in the same form.
Carried on voices
The chamber decided this amendment without a counted division, so there is no list of individual Aye and No votes.
Senate
Government amendments define GloBE securitisation entities and tighten the joint-and-several liability rules so they do not extend to those excluded entities.
Passed on the voices
The chamber agreed to this amendment package without a counted vote. APH records the agreed count by amendment, while the source documents are grouped into amendment sheets.
Parliamentary debate
Start here — lead voices
Leigh supports the bill as the administrative and legal machinery needed to put Australia’s global and domestic minimum tax in place for large multinationals.
Read in Hansard ↗Kennedy says the coalition will support the bill because it helps tax multinationals where their activity occurs, but he criticises Labor for broader tax increases and broken promises.
Read in Hansard ↗Spender supports the bill and says it will help make multinationals pay their fair share by aligning global minimum taxThe 15 per cent floor for large multinationals that this bill helps administer in Australia. rates and reducing profit shifting.
Read in Hansard ↗Tim Ayres supports the bill as the machinery needed to administer Australia’s new global and domestic minimum tax regime for large multinationals.
Read in Hansard ↗All speeches by bloc
10 speakers · 11 contributions · 10 support
“Schedule 1 to the Bill implements consequential and miscellaneous provisions necessary for the administration of the global and domestic minimum taxes in Australia, including amendments to ensure the taxes interact appropriately with existing Australian taxation laws.”Read the full speech in Hansard ↗
“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.”Read the full speech in Hansard ↗
“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.”Read the full speech in Hansard ↗
“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.”Read the full speech in Hansard ↗
“I'm pleased to rise today to speak in support of this bill, the Taxation (Multinational—Global and Domestic Minimum Tax) Bill 2024.”Read the full speech in Hansard ↗
“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.”Read the full speech in Hansard ↗
“The economic impact of these reforms cannot be overstated. Economists estimate that close to 40 per cent of multinational profits, which is roughly equivalent to around $900 billion, has shifted to low-tax countries each and every year. This has a devastating impact on the revenue base of countries like ours, where corporate tax comprises a significant portion of our total revenue. The OECD estimates that, by making multinationals pay a minimum effective tax rate of 15 per cent, annual global revenue gains could exceed $300 billion. For Australia, the benefits of these reforms are crystal clear. By ensuring that multinationals pay their fair share of tax, we're protecting our revenue base, levelling the playing field for Australian businesses and ensuring that the benefits of economic activity in Australia are shared more broadly with the Australian people. At the same time, we're positioning Australia as a leader in global tax reform and setting a new standard for transparency, fairness and accountability in the international tax system. I commend the bill to the House.”Read the full speech in Hansard ↗
“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.”Read the full speech in Hansard ↗
“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.”Read the full speech in Hansard ↗
Hansard records 2 separate contributions by Andrew Leigh on this bill. They are grouped here so the speaker is listed once.
Minister's second reading speech
Leigh supports the bill as the administrative and legal machinery needed to put Australia’s global and domestic minimum tax in place for large multinationals. He says it preserves existing corporate tax settings and integrity rules while making the new taxes work with Australia’s tax system and treaties.
“This bill is part of a package of three bills which together will 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 (approximately A$1.2 billion) or greater.”Read this contribution in Hansard ↗
Second reading speech
Leigh supports the bill and says it will help Australia implement a 15 per cent global and domestic minimum tax for large multinationals, protect the revenue base, and reduce profit shifting. He presents it as a landmark reform that strengthens tax integrity and supports fair competition for domestic businesses.
“These bills represent a landmark achievement in the international tax landscape and follow on from the government's 2023-24 budget announcement that we would implement global and domestic minimum taxes for large multinational enterprises.”Read this contribution in Hansard ↗
8 speakers · 8 support
“Australians deserve a government focused on the challenges they face today. Yes; we agree with the government on this legislation. But we do not apologise for holding the government to account for their broken promises on tax, for the cratering productivity numbers and for their failure to fight inflation.”Read the full speech in Hansard ↗
“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.”Read the full speech in Hansard ↗
“Australians deserve a government that is focused on the challenges that Australians are facing today. Whilst we won't oppose this legislation, we do not apologise for continuing to hold the government to account for their broken promises on taxes, their failure to take action on productivity and the living standards it depends on and their failure to make fighting inflation their first, second and third priorities.”Read the full speech in Hansard ↗
“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.”Read the full speech in Hansard ↗
“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.”Read the full speech in Hansard ↗
“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.”Read the full speech in Hansard ↗
“The changes to multinational tax arrangements in this bill do not make up for Labor's attacks on aspirational Australians. These changes do not compensate for Labor's inaction on inflation. They do not address the impact of rising interest rates on Australian households, nor do they undo the harm caused by Labor's tax policies. Australians deserve a government that's focused on the challenges they face today. 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. We will not apologise for holding the government to account for 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, to improve productivity and to restore confidence in our economy.”Read the full speech in Hansard ↗
“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.”Read the full speech in Hansard ↗
2 speakers · 2 support
“This bill implements internationally agreed rules to ensure that multinational corporations with an annual global revenue of A$1.”Read the full speech in Hansard ↗
“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.”Read the full speech in Hansard ↗
2 speakers · 2 support
“I welcome this bill and support the intentions of aligning global minimum tax rates to ensure that corporations pay their fair share of tax, regardless of where they're based. But more needs to be done urgently to address the other issues front of mind for Australians in which the tax system has an important role to play.”Read the full speech in Hansard ↗
“This bill provides improved fairness across the global economy. It is an appropriate reform and one that I certainly support. I thank the House.”Read the full speech in Hansard ↗
Record
House · Introduced and read a first time
Introduced
The bill was formally presented to the chamber and read a first time, which starts its parliamentary journey.
House · Second reading moved
Second reading opened
A minister or sponsoring member moved the second reading, opening the main debate on the bill's purpose and principles.
House · Second reading debate
Second reading debate
The bill reached this recorded parliamentary step.
House · Referred to Federation Chamber
Referred to Federation Chamber
The bill reached this recorded parliamentary step.
House · Second reading debate
Second reading debate
The bill reached this recorded parliamentary step.
House · Second reading debate
Second reading debate
The bill reached this recorded parliamentary step.
House · Second reading agreed to
Second reading agreed
The chamber agreed to the bill at second reading, meaning it accepted the bill in principle and allowed it to continue.
House · Reported from Federation Chamber
Reported from Federation Chamber
The bill reached this recorded parliamentary step.
House · Third reading agreed to
Third reading agreed
The chamber agreed to the bill at third reading, which completed passage through that chamber.
Senate · Introduced and read a first time
Introduced
The bill was formally presented to the chamber and read a first time, which starts its parliamentary journey.
Senate · Second reading moved
Second reading opened
A minister or sponsoring member moved the second reading, opening the main debate on the bill's purpose and principles.
Senate · Second reading debate
Second reading debate
The bill reached this recorded parliamentary step.
Senate · Second reading debate
Second reading debate
The bill reached this recorded parliamentary step.
Senate · Second reading agreed to
Second reading agreed
The chamber agreed to the bill at second reading, meaning it accepted the bill in principle and allowed it to continue.
Senate · Committee of the whole: amendments considered
Amendment packages agreed
The chamber considered amendments before the bill moved to the next stage.
Senate · Third reading agreed to
Third reading agreed
The chamber agreed to the bill at third reading, which completed passage through that chamber.
House · Consideration of Senate message
House agreed to Senate amendments
The House dealt with Senate amendments or requests so both chambers could settle the bill in the same form.
Parliament · Finally passed both Houses
Passed both houses
Both houses passed the bill in the same form, completing parliamentary passage.
Assent · Assent
Assent
The Governor-General gave Royal AssentThe final step that turns a passed bill into an Act and makes the changes law., turning the bill into an Act.
Senate Economics Legislation Committee; Committee report (14/08/2024)
Referred to committee
Referred to Committee (4 July 2024): Senate Economics Legislation Committee; Committee report (14 Aug 2024)
APH bill page notes
