Qualified GloBE Taxes Determination 2025

The Determination establishes the framework for identifying qualified GloBE taxes under Australia's implementation of the OECD Pillar Two global minimum tax. Part 2 sets out definitions and criteria for Qualified IIRs (s.5), Qualified Domestic Minimum Top-up Tax (s.6), and QDMTT Safe Harbour status (s.7). Affected multinational enterprises with Australian operations subject to the 15% global minimum tax must ensure their tax positions align with these qualifying criteria.

For multinational groups caught by Pillar Two rules, this determination provides certainty on which taxes count toward the effective minimum rate and which safe harbour provisions may apply. Tax advisers and finance teams should review existing structures against the qualified IIR and QDMTT definitions to assess compliance positioning under Australia's new global minimum tax regime.