Using this API product
Description
Australia has implemented the Global Anti-Base Erosion Model Rules by introducing a global and domestic minimum tax.
This API product allows clients and their authorised agents to lodge, via their software products, directly to the ATO for one or multiple entities within their multinational enterprise (MNE) group, covering the following obligations in a combined form:
Foreign Lodgment Notification (FN)
Notify the ATO that a foreign entity will lodge the GloBE Information Return to a foreign government agency on their behalf.
- Australian Income Inclusion Rule (IIR)
Applies a top-up tax on Australian parent entities if the group’s effective tax rate in another jurisdiction is below 15%.
- Australian Undertaxed Profits Rule (UTPR)
Acts as a backstop to the IIR, applying a top-up tax on Australian constituent entities when profits are not taxed under the IIR.
- Australian Domestic Minimum Top-up (DMT) Tax
Ensures Australia retains primary taxing rights over low-taxed profits within its jurisdiction, consistent with the GloBE Rules.
Clients and their agents can submit an original lodgment or an amendment via this API product. Amendments can only be lodged by the entity that submitted the original return.
In addition, you will receive a lodgment confirmation response, including payment reference numbers for entities that have liabilities to pay.
Business usage and process flow
The Global and Domestic Minimum Tax Product provides a suite of functionality that allows the adoption, design and lodgment of the Combined Global and Domestic Minimum Tax Return. The Global and Domestic Minimum Tax Product enables this by providing three APIs that can be used to lodge and/or amend the Combined Global and Domestic Minimum Tax Return and provides payment reference numbers (PRNs) for making payment towards liabilities reporting on the form.

The APIs that are part of this API Product to deliver this functionality are provided below:
- Global and Domestic Minimum Tax Return API
- Global and Domestic Minimum Constituent Entity Tax Return API
- PRN Retrieval API
Taxpayer
- The taxpayer, either the reporting party or by registered tax agent, will be able to lodge the Combined Global and Domestic Minimum Tax Return via the use of the above mentioned Global and Domestic Minimum Tax Return API.
- Tax liabilities for Constituent Entities (CEs) under the MNE group may be reported in the Combined Global and Domestic Minimum Tax Return when lodged to the ATO.
- Upon successful response from the Global and Domestic Minimum Tax Return API the ATO will receive the lodged tax return.
- The Global and Domestic Minimum Constituent Entity Tax Return API allows the reporting entity to report IRR, UTPR and DMT tax liabilities for a constituent entity within their MNE group. The taxpayer will also be able to retrieve Payment Reference Numbers (PRNs) directly for any constituent entity that has a liability greater than $0, using the above-mentioned PRN Retrieval API.
ATO
- ATO will return a lodgment confirmation or any errors that may happen during the lodgment of the return. A Payment Reference Number (PRN) will also be returned to the consuming application in order to make a payment to the ATO via existing channels
Authentication
Authorisation
The Global and Domestic Minimum Tax product allows a couple methods to authorise with the APIs that this product offers. The intermediary must have the appropriate authorisation for the interaction being performed on behalf of the client recorded in ATO systems. Below are the types of authorisations that are supported in this API Product.
Reporting Party Authorisation
- The reporting party identifying information being passed to the API must not be that of a sole trader
Intermediary - Registered Tax Agent Authorisation
- Registered tax agents must be appropriately linked to the business at an account or client level to use the service on behalf of the business
Authorisation to use the Global and Domestic Minimum Tax product must be set up before consumption, this is according to the normal Access Management process to ATO online service.
For more information around how to ensure everything is setup correctly for authorisation calls to the APIs that this product allows please refer to access manager authorisation.
End User
Reporting party: a lodging entity of the Combined Global and Domestic Minimum Tax Return can be either a Constituent Entity (CE) lodging on a standalone basis, or a Designated Local Entity (DLE) - a centralised filing entity on behalf of all Constituent Entities. Constituent Entities include Joint Ventures and any entities that are within scope of Global and Domestic Minimum Tax.
Intermediary – registered tax agent: a registered tax agent who has been appointed by the reporting party to act on their behalf at client level or GloBE account can lodge a combined Global and Domestic Minimum Tax Return for the reporting party and the entities within their MNE group.
Scopes
ato.apGlobalDomesticMinimumTax
Risk Rating
4 - High Risk
For more information, see API risk rating.
Rate Limit
Rate Limiting is Not Applicable at the API Product level
Test Scenarios
Currently test scenarios for sandbox testing haven't been created will be added here once added.
Production Requirements
Currently the production requirements are still getting gathered once available they will be added here.
Constituent APIs
API List
Global and Domestic Minimum Tax Return API
API specification
Global and Domestic Minimum Constituent Entity Tax Return API
API specification
Release notes
Initial version published for consultation