Public Country by Country Reporting – Why, Who, When and What

Public Country by Country Reporting – Why, Who, When and What.

Why

In an effort to promote international corporate tax transparency, the Australian Government requires certain multinational enterprises to publish group financial and tax information in a certain format to the Australian Taxation Office (ATO). This information will be later published on a publicly available website.

Who

The public CbCR regime applies to a parent of a multinational group that meets certain criteria including:

1. Group has Annual Global Income of $1 Billion (AUD) or more
2. $10 Million (AUD) or more was Australian sourced income
3. A member of the group is an Australian tax resident, or has a permanent establishment in Australia

Australian subsidiary companies belonging to these groups must already provide certain information (CbC local files) to the ATO each year. The public CbCR regime is in addition to that and applies to the parent entity.

When

The public CbCR regime applies to income years starting on or after 1 July 2024 and requires filing a report within 12 months of the end of the financial year. 

For example: CbCR Parent company year end

What

Group-wide figures must be disclosed including:

• Revenues, profits, and income taxes
• Core business activities and employee numbers
• Tangible assets
• Related and unrelated party revenues

The disclosures may vary based on jurisdiction:

• Australia and ‘specified jurisdictions’: Detailed, jurisdiction-level data required.       
• All other jurisdictions: Data can be disclosed either on a CbC or aggregated basis.

Compliance and penalties

The parent entity should register with the ATO for public CbC reporting and will be issued an Australian Reference Number (ARN) if it does not already have one, or an Australian Business Number (ABN).

The parent entity will be required to provide a report to the ATO using XML Schema software within 12 months of the end of the relevant financial year. If errors are identified after lodgement, correction must occur within 28 days of identification. Penalties can apply for non-compliance.

Certain entities may be able to apply for exemptions from providing some or all of the disclosures, although exemptions are limited. Detailed explanations will be required with exemption applications.

Registration forms are already available to complete and send to the ATO.

The ATO has recently issued Draft instructions about the Public CbC Report available for public comment.

How Exant Advisory can help

We can assist global parent entities with all compliance for Public Country by Country reporting including:

1. Assess public CbCR lodgement obligations and whether exemptions may be available
2. Assist with registration
3. Preparation of public CbC reports and filing with ATO

We expect that 2026 will be the start of a heavy compliance year in Australia for Significant Global Entities with CbC reporting; Pillar 2 reporting and now Public CbC Reporting so entities should prepare early to ensure the compliance can be prepared accurately and on time.

Should you require advice or assistance, please contact your usual Exant Advisor or alternatively our Tax partner Jamie Towers on 07 3218 3900 or via the form below.

Author: Jamie Towers