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Country by Country (CbC) Reporting

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Country-by-Country Reporting (CbCR) is a mandatory international tax transparency framework developed by the OECD as part of its Base Erosion and Profit Shifting (BEPS) Action 13 initiative. It requires large multinational enterprise (MNE) groups to prepare an annual report that sets out high-level financial and tax information for each jurisdiction in which they operate. The report is provided to tax authorities and shared between jurisdictions through information exchange agreements, supporting risk assessment and tax compliance activities.

Globally, CbCR applies to large MNE groups with consolidated global revenue at or above EUR 750 million (or the local currency equivalent) in the relevant income year, however, in Australia, the criteria is $1 Billion AUD of aggregated turnover.

A MNE parent entity and each subsidiary entity with income included in consolidated financial statements are each known as a CbC Reporting Entity (CBCRE).
In Australia, in addition to the CBC report prepared by the MNE parent entity, each CBCRE taxpayer must file:
  • CBC Master File – a detailed report describing the group’s financial information, geographical locations, intangible assets and international related party dealings. This is generally prepared by the parent entity and the report must be filed in English.
  • Local File – a report specific to the filing entity which describes its business and international related party dealings
These reports must be filed with the Australian Taxation Office (ATO) within 12 months of the end of the financial year and requires XML Schema software for lodgement. The ATO allows few exemptions, so even small Australian taxpayer members of a MNE group must complete the relevant CbC filing.

The Australian tax law also requires each corporate CBCRE taxpayer to file General Purpose Financial Statements (GPFS) with the ATO by the date of lodgement of the tax return, unless the company has already filed GPFS with the Australian Securities & Investments Commission on time.

It is critical that every CBCRE ensures all tax compliance is lodged on time as the Australian tax law for Significant Global Entities (SGE) applies penalties at the rate of 500 times that of other taxpayers.

Public Country by Country Reporting

While the above CBC reporting information is only provided to the ATO and is kept confidential, for financial years commencing on or after 1 July 2024, the Australian Government separately requires certain MNE Parent companies to register with the Australian Taxation Office (ATO) and publish group financial and tax information in a certain format. This information will be later published on a publicly available website. This new regime is known as Public Country by Country Reporting.

As this filing is separate to Australian CBCRE, parent companies must prepare early to ensure compliance is accurate and on time. Please refer to our article for further information here.

How Exant Advisory can help

Exant Advisory assists both CBCRE taxpayers and MNE parent companies.

Our experts assist CBCRE taxpayers to comply with the law including:

  • Preparation of GPFS for Australian groups or stand alone entities
  • Preparation and filing of CBC Local File (& Master File)

Our experts also assist MNE parent companies to register with the ATO and help prepare and file the Public CBC Report. 

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