International taxation – global and domestic minimum tax – amending legislation

In 2024, the Australian Government introduced a 15 per cent minimum tax for large companies.

The laws are based on rules agreed with the OECD Inclusive Framework.

The OECD rules make sure large companies pay at least 15 per cent tax.

Minor changes need to be made to the law to keep it consistent with the OECD rules.

The changes are based on OECD guidance on the rules.

We are consulting on these changes.

The main changes include:

• an equity investment inclusion election

• rules on qualified flow-through tax benefits

• an election for regulated mutual insurance companies

• rules on securitisation entities.

We would like your comments by 21 November 2025.

Related content

Previous consultations

• International taxation – global and domestic minimum tax – primary legislation

• International taxation – global and domestic minimum tax – subordinate legislation

• Global agreement on corporate taxation: addressing the tax challenges arising from the digitalisation of the economy