API Description
The Global and Domestic Minimum Constituent Entity Tax Return API enables software users to lodge a Combined Global and Domestic Minimum Tax Return on behalf of a constituent entity within their Multinational Enterprise (MNE) group. This API is to support the digital lodgment of tax returns for entities that are subject to Australia's implementation of the OECD's Global Anti-Base Erosion (GloBE) Rules. It facilitates the reporting of obligations under the following components:
Australian Income Inclusion Rule Tax (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 Tax (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 Tax (DMT)
Ensures Australia retains primary taxing rights over low-taxed profits within its jurisdiction, consistent with the GloBE Rules.
Effective Dates
- The IIR and DMT apply to fiscal years starting on or after 1 January 2024.
- The UTPR applies to fiscal years starting on or after 1 January 2025.
Use Cases
Use Case Flow: Global and Domestic Minimum Constituent Entity Tax Return API
Self-Assessment
The client (reporting entity or via tax agent) self-assesses their obligations to report under the following components:
- Australian Income Inclusion Rule Tax (IIR)
- Australian Undertaxed Profits Rule Tax (UTPR)
- Australian Domestic Minimum Top-up Tax (DMT)
Lodgment of the Global and Domestic Minimum Constituent Entity Form(s)
- The Global and Domestic Minimum Constituent Entity Tax Return API is used to submit a form for each Constituent Entity (CE) that is included in the Combined Global and Domestic Minimum Tax Return form, covering the IIR, UTPR, and DMT obligations.
- A Combined Global and Domestic Minimum Tax Return form is also required to be lodged via the Global and Domestic Minimum Tax Return API, covering the Foreign Lodgment Notification (FN), DMTR, and AGTR (IIR/UTPR) obligations for one or more entities in the MNE group.
ATO Processing
- The ATO receives the form which is used to post tax liabilities to each relevant Constituent Entity's account.
Lodgment Confirmation and Payment
- A lodgment confirmation is returned to the lodger, with a Payment Reference Number (PRN) for each Constituent Entity (CE). PRNs are requested via a related API.
- The user makes a payment to the ATO through existing payment channels.
Scopes
ato.apGlobalDomesticMinimumTax
Rate Limit
N/A will be added if required at API level.
Test Scenarios
N/A will be added when available
Response Messages
N/A will be added when available
Production Requirements
N/A will be added when available
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