API Description
The Global and Domestic Minimum Tax Return API allows software users to lodge a Combined Global and Domestic Minimum Tax Return directly to the Australian Taxation Office for one or multiple entities 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:
- Foreign Lodgment Notification (FN)
Notify the ATO that a foreign entity will lodge the GloBE Information Return with a foreign tax authority on behalf of the Australian entity.
- Australian Income Inclusion Rule (IIR) Tax
Applies a top-up tax on Australian parent entities when the group’s effective tax rate in another jurisdiction is below 15%.
- Australian Undertaxed Profits Rule (UTPR) Tax
Applies a top-up tax on Australian constituent entities when profits are not brought into charge under the IIR.
- Australian Domestic Minimum Top-up (DMT) Tax
Ensures Australia can impose a top-up tax on low-taxed domestic profits, in priority over the IIR and UTPR, consistent with the GloBE Rules.
Effective Dates
- The FN, 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 Tax Return API
Self-Assessment
The user (reporting entity or tax agent) self-assesses their obligations to report under the following components:
- Foreign Lodgment Notification (FN)
- Australian Income Inclusion Rule Tax (IIR)
- Australian Undertaxed Profits Rule Tax (UTPR)
- Australian Domestic Minimum Top-up Tax (DMT)
Lodgment of the Combined Form
A combined form is submitted through the Global and Domestic Minimum Tax Return API covering the FN, DMTR, IIR and UTPR obligations for one or more entities in the MNE Group.
ATO Processing
- The ATO receives the form and issues a lodgment receipt.
- It also receives the associated constituent entity data (via a related API), which is used to post tax liabilities to each relevant Constituent Entity's (CE) account.
Lodgment Confirmation and Payment
- A lodgment confirmation is returned to the lodger.
- A Payment Reference Number (PRN) is 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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