Pillar Two notifications in Australia and the EU: the filing most groups underestimate

Across the first live GloBE cycle we delivered close to 500 filings in more than ten jurisdictions, including over 150 GIRs. The returns were rarely where groups came unstuck. The notifications were.

A notification carries no tax, no computation, and often only a handful of data points. That is exactly why it gets missed. And where a group relies on central filing, the notification is the mechanism that makes the relief work. Without it, the exemption does not apply, the local filing obligation snaps back, and penalties begin running on a return nobody prepared.

Australia and the EU both make the point, in different ways.

Australia: the notification sits inside the return

Australia’s foreign lodgment notification is not a standalone form. In March 2026 the ATO consolidated the foreign lodgment notification, the Australian IIR/UTPR tax return and the domestic minimum tax return into a single Combined Global and Domestic Minimum Tax Return. The GIR is not part of it and remains a separate lodgment. If your group files its GIR overseas and assumes nothing is due in Australia, that assumption fails: the notification lives inside a return you still have to lodge.

Australia runs an 18-month deadline for the first fiscal year in scope and 15 months thereafter, applied consistently across the GIR, the foreign lodgment notification, the AIUTR and the DMTR. For a 31 December 2024 year end, the first filings fell due at the end of June 2026.

Australia has adopted the OECD common understanding. The ATO will not require local GIR lodgment, and will not impose penalties, where three conditions hold together:

• There is no qualifying competent authority agreement in effect, because no exchange relationship has been activated with the jurisdiction of filing.
• The GIR is lodged on time in a 2024 implementing jurisdiction named in the OECD annexe.
• A foreign lodgment notification has been submitted through the CGDMTR.

All three. The notification is not the soft condition — it is the one entirely within your control, and the one most often skipped.

Two further points catch groups out.

First, the deferral is narrower than it reads, and the distinction it turns on is one many groups missed. The automatic 30-day deferral for the 2024 fiscal year covers the AIUTR and the DMTR only. Neither the GIR nor the foreign lodgment notification can formally be deferred at all.

The foreign lodgment notification does attract an automatic 30-day suspension of lodgment enforcement for fiscal years starting in 2024, aligned to that deferral. But a suspension of enforcement is forbearance, not a new due date — the obligation remains outstanding throughout. For the GIR, not even that is automatic: the ATO may consider a suspension during the transition period, and it has to be requested separately. None of it moves the payment date either. Top-up tax stays due on the original timetable unless a payment deferral is applied for and granted.

Second, filing the GIR abroad does not clear the decks. Obligations to lodge the CGDMTR, including the DMTR and AIUTR, remain even where the GIR is lodged overseas, and an Australian group entity retains a GIR lodgment obligation even where the Australian top-up tax amount is nil.

Check the exchange list before you rely on it. Australia signed the Multilateral Competent Authority Agreement on the Exchange of GloBE Information on 28 January 2026, but signature is not activation. As at 1 April 2026 Australia had activated bilateral relationships with Austria, Denmark, Hungary, South Korea, Liechtenstein, Norway, Slovenia, South Africa and the United Kingdom. That list is shorter than most groups assume, and it changes.

The EU: one return, twenty-seven implementations

Article 44 of the Pillar Two Directive sets the default: each constituent entity files in the member state where it is located. The derogation applies where the ultimate parent or a designated filing entity files for the whole group, conditional on an information exchange agreement being in effect.

DAC9 makes that workable. Member states had to transpose by 31 December 2025. For a fiscal year aligned to calendar 2024, the first GIR was due 30 June 2026, with exchanges between authorities completed by 31 December 2026 and none taking place before 1 December 2026. The filing member state must communicate to other member states within three months, extended to six months for the first reporting year.

The trap is not the directive. It is what sits beneath it. Member states diverge in how they allocate the obligation: some use a designated or liable entity model, others rely on optional appointments, local allocation rules, or entity-by-entity filing. One central return does not produce one central obligation. The Netherlands and Luxembourg both require confirmation of where the GIR was centrally filed, on their own local terms and their own forms.

So a group filing centrally in one member state may still owe notifications in five others, each with different content, different mechanics, and no shared deadline logic. There is no consolidated view of this. Someone has to hold the matrix.

What this means in practice