CbC Reporting: ATO Guidance

The ATO has released guidance on the implementation of Country-by-Country (CbC) reporting in Australia.

The ATO guidance outlines its administrative practice, including advice on CbC reporting, to assist taxpayers in understanding and meeting reporting obligations for significant global entities).

It supplements and should be read with Law Companion Guideline LCG 2015/3 (issued 17 December 2015).

According to the ATO, the three types of statements required under the CbC reporting regime correspond to the master file, local file and CbC report in Annexes I, II and III to Chapter V of the final report.

The ATO has approved forms for each of these statements.

“Country-by-country (CBC) reporting is part of a broader suite of international measures aimed to combat tax avoidance.”

Marius Fourie - Director & Business Advisor

About the author

Marius Fourie - Director & Business Advisor

As Director and Business Advisor, Marius uses his accounting expertise and empathetic skills to work directly with business owners and help them feel at ease with their finances.

Marius saw a common need in clients that just wasn’t being met by accounting providers.

That need was for clear, open communication and streamlined accounting services that didn’t come padded out with any unnecessary features.

Business owners just don’t have time to compare different accounting firms to see which one has the best packages with the best inclusions (many of which they would pay for but never use).

Key Takeaways

CBC reporting is essential for large multinational groups — it promotes global tax transparency and helps combat base erosion & profit shifting.

CBC reporting is essential for large multinational groups — it promotes global tax transparency and helps combat base erosion & profit shifting.

Multinationals with sufficient size or presence must disclose by-jurisdiction data on profits, taxes, employees and assets.

If your group’s consolidated global income meets the threshold (AUD 1 billion or more), you should assess whether you are a CBC reporting entity.

If your group’s consolidated global income meets the threshold (AUD 1 billion or more), you should assess whether you are a CBC reporting entity.

Eligibility depends not only on income, but also on group structure (whether consolidated or a notional listed company group) under the legislation.

CBC reporting requires multiple components: CBC report, master file and local file — simplified or full depending on group size and structure.

CBC reporting requires multiple components: CBC report, master file and local file — simplified or full depending on group size and structure.

Recent updates include a new Short-Form Local File option for certain entities.

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Frequently Asked Questions

What is CBC reporting under Australian tax law?

CBC reporting requires certain multinational groups to submit a report to the ATO that discloses — by jurisdiction — financial data such as revenues, profits, taxes paid, number of employees, and assets. It’s designed to enable tax authorities to assess whether the group’s global profits align with taxes paid in each country.

Which entities are required to lodge CBC reports?

An entity must lodge if it is a “CBC reporting parent” (global parent) or a member of a “CBC reporting group” whose consolidated global income meets the threshold (typically AUD 1 billion or more) — or when a foreign entity with a permanent establishment in Australia meets certain conditions.

What documents must be lodged under CBC reporting?

Affected groups must submit three documents: the CBC report itself, a “master file” and a “local file” (or a short-form version depending on the group and the year).

When must CBC reports be lodged?

CBC statements must be lodged within 12 months after the end of the income year to which they relate.

What changes have been made recently to the CBC regime in Australia?

From 1 July 2024, a new “Public CBC” regime takes effect. This requires large multinational groups with an Australian presence to publish certain global financial and tax data publicly. This adds a transparency layer on top of the existing confidential CBC regime.

What is Country-by-Country (CbC) reporting?

Country-by-Country reporting is a reporting regime that requires certain large multinational groups to provide detailed tax and financial information by tax jurisdiction to the Australian Taxation Office (ATO), helping ensure transparency and compliance with international tax standards.

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