Public country-by-country (CBC) reporting
- G H
- Jun 13
- 4 min read
What is Public CBC reporting
Public country-by-country (CBC) reporting is a regime (the regime) that requires certain large multinational enterprises to publish selected tax information to the public. This information must be reported either on a CBC basis or on an aggregated basis. Under the regime, the parent entity generally has the reporting obligation, rather than the Australian subsidiary (Public CBC reporting parent).
The regime applies for reporting periods starting from 1 July 2024. For a Public CBC reporting parent with a reporting period end of 30 June, this will be from 1 July 2024. Reports are due within 12 months of the end of the reporting period.
If a Public CBC reporting parent has a reporting period that does not end on 30 June, the regime will first apply from the start of the relevant period that occurs after 1 July 2024. For example, if a Public CBC reporting parent's reporting period is from 1 April to 31 March, the regime will first apply for its reporting period starting 1 April 2025, with the first report due before 31 March 2027.
The Public CBC reporting parent publishes their Public CBC report by providing selected tax information to the ATO in the approved form. We then facilitate the publication of the information on an Australian Government website.
Public CBC reporting provides information to the public and enables better assessment of 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.
Note: Public CBC reporting and country-by-country (CbC) reporting are different measures. For information about CBC reporting, go to Country-by-country reporting.
Who is required to report
An entity must report for a reporting period if all of the following apply:
it is a CBC reporting parent for the preceding period
it is an entity of the type specified
it satisfies the requirements for that reporting period.
An entity is of the specified type 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.
'Constitutional corporation' means a foreign corporation (one not formed within Australia), or a trading or financial corporation formed within the limits of the Commonwealth.
An entity satisfies the requirements for a reporting period if all of the following apply:
it was a CBC reporting parent for a period that includes the whole or a part of the preceding reporting period
it was a member of a CBC reporting group at any time during the reporting period
at any point during the reporting period, it, or a member of its CBC reporting group, was an Australian resident or a foreign resident operating an Australian permanent establishment
$10 million or more of its aggregated turnover for the reporting period was Australian-sourced
it was not an exempt entity or included in a class of exempt entities.
An entity is a CBC reporting parent for a reporting period if all of the following apply:
it is not an individual
if it is a member of a CBC reporting group at the end of the period; it is not controlled by any other member of the CBC reporting group at the end of the period
its annual global income for the period is $1 billion or more.
Registration by Public CBC reporting parents
Registration by Public CBC reporting parents allows for more efficient processing and helps to simplify the process of:
giving the Public CBC report to the ATO
requesting an extension of time to provide the Public CBC report
requesting an exemption from reporting obligations for a reporting period.
The registration process doesn't differentiate between resident and non-resident Public CBC reporting parents. A non-resident Public CBC reporting parent without an ATO reference number (ARN) will be automatically issued with an ARN as part of this registration process.
Registration is also beneficial as it enables a Public CBC reporting parent entity to provide authorisation for representatives to act on its behalf. This includes having representatives satisfy its obligations, such as lodging the Public CBC report or applying for a Public CBC reporting exemption. Representatives can include:
designated officers or employees of the CBC reporting parent
an authorised representative of the Australian subsidiary
an adviser
other nominated person.
The Public CBC registration form is in a fillable portable document format (PDF), and lodgment is via email. Upon lodgment, we will send an email acknowledging receipt.
To get the form, see Public country-by-country (CBC) registration form (NAT 75645). You can also read the Instructions to complete Public country-by-country registration.
Public CBC reporting obligations
The reporting obligation is on the Public CBC reporting parent (whether located overseas or in Australia) to report selected tax information to us.
An Australian subsidiary of a foreign entity generally does not have any reporting obligation of its own for a reporting period. An exception to that general principle is if a foreign entity does not include the Australian subsidiary in its group’s consolidated accounts, and the Australia subsidiary qualifies as a Public CBC parent entity in its own right.
The Public CBC reporting parent entity must give the Public CBC report electronically in the approved form 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 us within 28 days of the Public CBC reporting parent identifying or otherwise becoming aware of that error.
Penalties apply for non-compliance.
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