Give feedback on changes to the law for the minimum tax for large companies.
Minimum tax
The Australian Government introduced a 15 per cent minimum tax for large companies in 2024.
The law is based on rules agreed with the OECD Inclusive Framework.
The OECD rules make sure large companies pay at least 15 per cent tax.
Law changes
We need to make minor changes to the law to keep it consistent with the OECD rules.
The changes are based on OECD guidance on the rules.
The changes:
refine the allocation of income and taxes for flow-through and hybrid entities
clarify certain tax allocation rules
modify when substitute loss carry-forward deferred tax assets arise
make sure Safe Harbours work as intended.
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Related content
International taxation – global and domestic minimum tax – amending legislation (February 2026)
International taxation – global and domestic minimum tax – amending legislation (October 2025)
International taxation – global and domestic minimum tax – primary legislation
International taxation – global and domestic minimum tax – subordinate legislation
