October 4, 2022
Australian Treasury releases consultation paper on BEPS 2.0 two-pillar global agreement
The Australian Treasury has released a consultation paper seeking submissions to help inform the Australian Government on how to design and implement the proposed OECD/G20 BEPS 2.0 two-pillar global agreement domestically - Global agreement on corporate taxation: addressing the tax challenges arising from the digitalisation of the economy.
The paper poses 40 consultation questions on how the two-pillar global corporate tax agreement would operate in Australia, and how Australian stakeholders view the benefits, challenges and impacts, including:
Design of the two-pillar global agreement
This section comprises 16 overview questions on both Pillar One and Pillar Two, focusing on the overarching design of the two-pillar multilateral agreement. These questions seek input on issues such as why there should be a global agreement on corporate taxation, the economic outcomes, estimated revenue impacts, and potential compliance costs/impacts for large multinationals.
Australian implementation of the GloBE Model Rules
This section comprises 24 questions on the GloBE Model Rules (Pillar Two) implementation in Australia, which address issues such as the potential mode of implementation, implementation timing, administrative provisions and safe harbors. Noteworthy issues include:
Treasury is accepting submissions by 1 November 2022.
For additional information with respect to this Alert, please contact the following:
Ernst & Young (Australia), Sydney
Ernst & Young (Australia), Perth
Ernst & Young (Australia), Melbourne
Ernst & Young LLP (United States), Australia Tax Desk, New York
Ernst & Young LLP (United Kingdom), Australia Tax Desk, London