What is Public CBC reporting?
Public CBC reporting is a reporting regime which requires certain large multinational enterprises to publish selected tax information. The information must be reported either on a CBC basis or on an aggregated basis. The regime applies for reporting periods commencing from 1 July 2024.
The entities within the regime publish their Public CBC report by providing it to the ATO and then the ATO uploading it on data.gov.au. Public CBC reporting improves how information is shared with the public to help compare entity tax disclosures, to better assess whether an entity's economic presence in a jurisdiction aligns with the amount of tax they pay in that jurisdiction.
Public CBC reporting requires disclosures about:
the revenues, profits and income taxes of the global group
the activities of the global group
an entity's international related party dealings.
Who is required to report?
An entity must report for a reporting period if all of the following apply to it:
is a Public CBC reporting parent for the preceding period
is an entity of the type specified
satisfies the requirements for that reporting period.
An entity is of the type specified if it is any one of the following:
constitutional corporation
trust, provided each of the trustees is a constitutional corporation
partnership, provided each of the partners is a constitutional corporation.
Entities meet the requirements for a reporting period if all of the following apply:
they were a Public CBC reporting parent for a period that includes the whole or a part of the preceding reporting period
they were a member of a Public CBC reporting group at any time during the reporting period
at any point during the reporting period, they, or a member of their Public CBC reporting group, were an Australian resident or a foreign resident operating an Australian permanent establishment
$10 million or more of their aggregated turnover for the reporting period was Australian-sourced
they were not an exempt entity or included in a class of exempt entities.
Public CBC reporting registration
All Public CBC reporting parents are encouraged to register with the ATO as this simplifies:
the giving of the Public CBC report to the ATO
requesting an extension of time to provide the Public CBC report
requesting an exemption from reporting obligations.
The registration form and instructions are under development and will be made available in 2025.
Public CBC reporting obligations
The Public CBC reporting parent entity must give the Public CBC report electronically to the ATO within 12 months after the end of the relevant reporting period.
An update to correct any material errors must be given to the ATO within 28 days of the Public CBC reporting parent identifying or otherwise becoming aware of that error.
Penalties apply for non-compliance.
The Public CBC reporting form and instructions are in development, they will be made available in 2025.
What does jurisdictional reporting mean?
For Australia and specified jurisdictions determined by the Minister, particular information must be published on a CBC basis.
For all other jurisdictions the CBC reporting group operates in, the Public CBC reporting parent has a choice to publish that same information on either a CBC basis or an aggregated basis.
Specified jurisdictions list
The Minister's determination of jurisdictions for the purpose of Public CBC reporting is provided by legislative instrument. The Taxation Administration (Country by Country Reporting Jurisdictions) Determination 2024Opens in a new window outlines the specified jurisdictions.
Jurisdictions that have a comprehensive international tax agreement with Australia:
Singapore
Switzerland
Other jurisdictions:
Andorra
Anguilla
Antigua and Barbuda
Aruba
Barbados
Bahamas
Bahrain
Belize
Bermuda
British Virgin Islands
Cayman Islands
Cook Islands
Curacao
Dominica
Gibraltar
Grenada
Guernsey
Hong Kong
Isle of Man
Jersey
Liberia
Mauritius
Monaco
Montserrat
Nauru
Niue
Panama
Republic of the Marshall Islands
Saint Kitts and Nevis
Saint Lucia
Saint Maarten (Dutch Part)
Saint Vincent & the Grenadines
Samoa
San Marino
Seychelles
Turks and Caicos Islands
US Virgin Islands
Vanuatu
Public CBC information to be reported
The Public CBC reporting parent is required to publish:
its own legal name
the names of each entity in the CBC reporting group
a description of the CBC reporting group’s approach to tax
information about Australia and specified jurisdictions, on a CBC basis
information about its other jurisdictions, either on a CBC or aggregated basis.
Information required to be reported
If the Public CBC reporting parent chooses to report on a CBC basis for all jurisdictions that the group operates in, it does not need to publish any information on an aggregated basis. However, if the Public CBC reporting parent only publishes information on a CBC basis for Australia and the specified jurisdictions, it must publish information for all other jurisdictions on an aggregated basis.
Australia and specified jurisdictions
The information required to be reported for Australia and specified jurisdictions is:
the name of the jurisdiction
a description of main business activities
the number of employees (on a full-time equivalent basis) at the end of the reporting period
revenue from unrelated parties
revenue from related parties that are not tax residents of the jurisdiction
profit or loss before income tax
book value at the end of the reporting period of tangible assets, other than cash and cash equivalents
income tax paid (on a cash basis)
income tax accrued (current year)
the reasons for the difference between income tax accrued (current year) and the amount of income tax due if the income tax rate applicable to the jurisdiction were applied to profit and loss before income tax
the currency used in calculating and presenting the above information.
Other jurisdictions (aggregated information)
The information required to be reported on an aggregated basis, for all other jurisdictions the group operates in, is, the aggregation of the following for all of those jurisdictions:
a description of main business activities in those jurisdictions
the number of employees (on a full-time equivalent basis) at the end of the reporting period
revenue from unrelated parties
revenue from related parties that are not tax residents of the jurisdiction in which that revenue is being derived
profit or loss before income tax
book value at the end of the reporting period of tangible assets, other than cash and cash equivalents
income tax paid (on a cash basis)
income tax accrued (current year)
the currency used in calculating and presenting the above information.
The information required to be reported, has been adopted from the Global Reporting Initiative (GRI) 207: Tax 2019 reporting standard. The GRI 207 may be used as a source of guidance in interpretating the publishing requirements. Regard may also be had to the BEPS Action 13 Guidance and the OECD Transfer Pricing Guidelines where they provide greater detail on the interpretation of terms.
GRI − Topic Standard for TaxOpens in a new window
BEPS Action 13 GuidanceOpens in a new window
OECD Transfer Pricing GuidelinesOpens in a new window.
Correction of errors
If a Public CBC reporting parent becomes aware of a material error contained in any of the information that has been published, the CBC reporting parent must correct the error by giving corrected information to the Commissioner in the approved form. This is required no later than 28 days after the entity becomes aware of the material error.
Penalties apply for non-compliance.
Publishing the information
The Public CBC reporting parent is required to publish the information on an Australian government website by giving the information in the approved form to the Commissioner.
The Public CBC reporting form and instructions are under development and will be made available in 2025.
The Commissioner’s role
The Commissioner will facilitate publication of the reported information as soon as practicable, on the Australian government website data.gov.au.
If a material error is corrected by the Public CBC reporting parent, the Commissioner will publish the corrected information on data.gov.au as soon as practicable.
The first publication is expected to be released in late 2026.
Extension of time to provide the Public CBC report
The Public CBC report is due within 12 months after the end of the relevant reporting period. For example, for the reporting period ending 30 June 2025, the Public CBC report is due by 30 June 2026.
A Public CBC reporting parent may apply to the Commissioner for an extension of time to provide the Public CBC report. A Public CBC reporting parent does not have to register to request an extension of time, but consideration and processing of the request may be delayed if it is not registered.
Guidance on extension of time requests will be made available in 2025.
Exemptions
The primary purpose of the Public CBC regime is to enhance tax transparency. However, a Public CBC reporting parent may seek an exemption from reporting obligations, from the Commissioner. The Commissioner may exempt an entity (a 'full exemption') or specify that an entity is exempt from publishing information of a particular kind (a 'partial exemption') for a single reporting period.
A Public CBC reporting parent does not have to register to request an exemption, but consideration and processing of the request may be delayed if it is not registered.
Guidance on exemptions will be made available in 2025. For more information, see Public country-by-country reporting transparency measure and exemption discretions.
