Taxation (Multinational—Global and Domestic Minimum Tax) (Qualified GloBE Taxes) Determination 2025

Taxation (Multinational—Global and Domestic Minimum Tax) (Qualified GloBE Taxes) Determination 2025

made under the Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024

Compilation No. 1

Compilation date: 21 March 2026

Includes amendments: Taxation (Multinational—Global and Domestic Minimum Tax) (Qualified GloBE Taxes) Amendment (Measures No. 1) Determination 2026

Prepared by The Treasury

About this compilation

This compilation

This is a compilation of the Taxation (Multinational—Global and Domestic Minimum Tax) (Qualified GloBE Taxes) Determination 2025 that shows the text of the law as amended and in force on 21 March 2026 (the compilation date).

The notes at the end of this compilation (the endnotes) include information about amending laws and the amendment history of provisions of the compiled law.

Uncommenced amendments

The effect of uncommenced amendments is not shown in the text of the compiled law. Any uncommenced amendments affecting the law are accessible on the Register (www.legislation.gov.au). The details of amendments made up to, but not commenced at, the compilation date are underlined in the endnotes. For more information on any uncommenced amendments, see the Register for the compiled law.

Application, saving and transitional provisions for provisions and amendments

If the operation of a provision or amendment of the compiled law is affected by an application, saving or transitional provision that is not included in this compilation, details are included in the endnotes.

Modifications

If the compiled law is modified by another law, the compiled law operates as modified but the modification does not amend the text of the law. Accordingly, this compilation does not show the text of the compiled law as modified. For more information on any modifications, see the Register for the compiled law.

Self‑repealing provisions

If a provision of the compiled law has been repealed in accordance with a provision of the law, details are included in the endnotes.

Contents

Part 1—Preliminary

1  Name 

3  Authority

4  Definitions

Part 2—Qualified GloBE taxes

5  Qualified IIRs

6  Qualified Domestic Minimum Top-up Tax

7  QDMTT Safe Harbour status

Endnotes

Endnote 1—About the endnotes

Endnote 2—Abbreviation key

Endnote 3—Legislation history

Endnote 4—Amendment history

Part 1—Preliminary

1  Name

  This instrument is the Taxation (Multinational—Global and Domestic Minimum Tax) (Qualified GloBE Taxes) Determination 2025.

3  Authority

  This instrument is made under the Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024.

4  Definitions

Note: Expressions have the same meaning in this instrument as in the Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024 as in force from time to time—see paragraph 13(1)(b) of the Legislation Act 2003.

In this instrument:

Domestic Minimum Top-Up Tax means a tax that is consistent with paragraphs (a) and (b) of the meaning of Qualified Domestic Minimum Top-up Tax in Article 10.1 of the GloBE Rules.

the Rules means the Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024.

Part 2—Qualified GloBE taxes

5  Qualified IIRs

  For the purposes of paragraph 10-15(a) of the Rules, a tax that is imposed under an IIR of a jurisdiction mentioned in Column 1 of an item in the following table, is specified as a Qualified IIR, for the Fiscal Year starting on or after the date specified in Column 2 of that item and each later Fiscal Year.

6  Qualified Domestic Minimum Top-up Tax

  For the purposes of paragraph 10-15(b) of the Rules, a tax that is a Domestic Minimum Top-up Tax, and is imposed under a law of a jurisdiction mentioned in Column 1 of an item in the following table, is specified as a Qualified Domestic Minimum Top-up Tax, for the Fiscal Year starting on or after the date specified in Column 2 of that item and each later Fiscal Year.

7  QDMTT Safe Harbour status

  For the purposes of subsection 8-200(2) of the Rules, the Qualified Domestic Minimum Top-up Tax of a jurisdiction specified in Column 1 of an item of the following table has QDMTT Safe Harbour status for the Fiscal Year starting on or after the date specified in Column 2 of that item and each later Fiscal Year.

Endnotes

Endnote 1—About the endnotes

The endnotes provide information about this compilation and the compiled law.

The following endnotes are included in every compilation:

Endnote 1—About the endnotes

Endnote 2—Abbreviation key

Endnote 3—Legislation history

Endnote 4—Amendment history

Abbreviation key—Endnote 2

The abbreviation key sets out abbreviations that may be used in the endnotes.

Legislation history and amendment history—Endnotes 3 and 4

Amending laws are annotated in the legislation history and amendment history.

The legislation history in endnote 3 provides information about each law that has amended (or will amend) the compiled law. The information includes commencement details for amending laws and details of any application, saving or transitional provisions that are not included in this compilation.

The amendment history in endnote 4 provides information about amendments at the provision (generally section or equivalent) level. It also includes information about any provision of the compiled law that has been repealed in accordance with a provision of the law.

Misdescribed amendments

A misdescribed amendment is an amendment that does not accurately describe how an amendment is to be made. If, despite the misdescription, the amendment can be given effect as intended, then the misdescribed amendment can be incorporated through an editorial change made under section 15V of the Legislation Act 2003.

If a misdescribed amendment cannot be given effect as intended, the amendment is not incorporated and “(md not incorp)” is added to the amendment history.

Endnote 2—Abbreviation key

Endnote 3—Legislation history

Endnote 4—Amendment history