Effective for reporting periods starting on or after 1 July 2024, the Australian Government has now introduced Public Country-by-Country (CBC) Reporting. This new measure requires large multinational groups with an Australian presence to publicly disclose details about their global tax and financial information to the Australian Taxation Office (ATO). The information will then be made publicly available to enhance greater transparency and accountability in how global businesses are taxed and operate across jurisdictions.

Who is affected?

Public CbC Reporting applies to a range of structures including trusts, partnerships and constitutional corporations.

An entity specifically meets the requirements for a reporting period where:

It is a CbC Reporting Parent with annual global income of $1 billion AUD or more;
It is a member of a CbC Reporting group;
Has a member included in the CbC Reporting Group which is an Australian resident or foreign resident operating through an Australian permanent establishment;
Derives at least $10 million AUD of the Group’s turnover from Australian sources.

What are the requirements?

The Public CbC Reporting parent must prepare a Public CBC report each year and publish it on an Australian Government website within 12 months after the end of their income year. Reports will need to be lodged electronically in the ATO-approved XML format and made publicly available once processed.

The information that is required to be published is split between Australia (and specified jurisdictions) and all other jurisdictions.

For Australia and specified jurisdictions

For Australia and specified jurisdictions, which include Singapore and Switzerland this information includes but is not limited to:

The name of the jurisdiction;
Description of main business activities;
Number of employees in each jurisdiction;
Revenue from unrelated/related parties per jurisdiction;
Income tax paid and accrued as well as the difference between the accrual and tax due for each jurisdiction;
Currency used in calculating and presentation the information.

For all other jurisdictions, information pertaining to the above can be published on an aggregated basis.

Can I obtain an exemption and what are the penalties?

The ATO may grant exemptions only in very exceptional circumstances where public disclosure could cause commercial harm or raise national security concerns. Exemptions apply only to a single reporting period and require a written submission outlining the reasons for the request.

Failure to lodge, late lodgement, or not correcting material errors within 28 days of being aware can result in penalties of up to A$825,000 per reporting period consistent with the existing CbC Reporting Regime.

What are the next steps?

With the Public CBC Reporting obligations now in effect, entities should take proactive steps to comply and minimise the risk of penalties. These may include:

Data readiness – review data systems to ensure all required tax and financial information are accurately captured across worldwide jurisdictions;
Governance – strengthen internal governance and review processes to ensure accurate and compliant disclosures;
Transparency – develop clear explanations of the Group’s approach to tax governance, profit-to-tax differences and economic presence in each jurisdiction;
Collaboration – engage with different jurisdictional teams early to coordinate responsibilities, timelines and review procedures.

If you’d like to know more about how we could assist you with your international tax compliance obligations, please feel free to reach out.