Australia

Corporate - Taxes on corporate income

Last reviewed - 24 December 2024

Companies, other than those that qualify as a CCIV (see below), that are residents of Australia are subject to Australian income tax on their worldwide income. Generally, non-resident companies are subject to Australian income tax on Australian-sourced income only. However, where a company is resident in a country with which Australia has concluded a double taxation agreement (DTA), Australia's right to tax business profits is generally limited to profits attributable to a permanent establishment (PE) in Australia.

All companies are subject to a federal tax rate of 30% on their taxable income, except for ‘small or medium business’ companies, which are subject to a reduced tax rate of 25%. The reduced tax rate applies only to those companies that, together with certain 'connected' entities, fall below the aggregated turnover threshold of 50 million Australian dollars (AUD).

Integrity measures also ensure that a company will not qualify for the reduced rate unless the specifically defined passive income (including, among other things, interest, rents, and net capital gains) that it derives represents no more than 80% of its total assessable income for the year.

A new tax and regulatory framework applies to corporate collective investment vehicles (CCIVs) with effect from 1 July 2022. In general terms, a CCIV is a type of a company limited by shares that is used for funds management and for which the tax law applies to ensure that the income and gains of the entity are taxed on a flow-through basis to the investors.

Global minimum tax and domestic minimum tax

Australia has implemented the Global Anti-Base Erosion (GloBE) Rules, a key component of the OECD’s Two-Pillar Solution to address the tax challenges of digitalisation of the economy. Specifically, the following elements of the global minimum tax are legislated:

The Income Inclusion Rule, which applies for income years starting on or after 1 January 2024. This rule applies to Australian multinationals and Australian entities that are subsidiaries of a foreign-headquartered multinational located in a jurisdiction that has not implemented this rule.
The Undertaxed Profits Rule, which applies for income years starting on or after 1 January 2025. Where no Income Inclusion Rule applies, the Undertaxed Profits Rule will apply to foreign multinationals that operate in Australia.

In addition, a 15% domestic minimum tax applies to income years starting on or after 1 January 2024 for Australian operations of multinationals and will ensure that Australia retains taxing rights over undertaxed Australian profits.

The substantive computation of the above top-up taxes is included in subordinate legislation, which was registered on 23 December 2024.

The global minimum tax and the domestic minimum tax apply to large multinationals with annual global revenue of 750 million euros (EUR) or more, subject to certain exemptions.

For more detailed information and the most recent updates, please visit PwC’s Pillar Two Country Tracker.