Australian Guidance Addresses Group Restructures and Global Tax

Australia issued guidance Wednesday on how tax consolidated groups’ restructurings interact with the global minimum tax.

The Australian Taxation Office’s guidance, published on its website, covers group restructure rules and related transition rules regarding the global minimum tax and tax consolidated groups’ calculation of a jurisdiction’s effective tax rate.

The group restructure rules cover transfers of ownership interests and asset transfers. The guidance also covers how transactions are accounted for under multiple scenarios based on when the transfer took place.

• The global minimum tax, also known as Pillar Two of the 2021 Organization for Economic Cooperation and ...