March 8, 2026
Australia – Revises Public Country-by-Country (CbC) Reporting Disclosure Framework
Summary
The Australian Taxation Office (ATO) has introduced a public country-by-country (CbC) reporting framework requiring certain large multinational enterprise (MNE) groups to disclose jurisdiction-level tax and financial information. The regime applies to reporting periods beginning on or after July 1, 2024 and requires the reporting parent entity to submit the information to the ATO in an approved electronic form for publication on an Australian Government website. The disclosure includes financial and tax data by jurisdiction as well as a statement describing the group’s approach to taxation.
Key points
Public country-by-country reporting framework
The public CbC reporting regime requires specified multinational enterprise groups to disclose selected tax and financial information relating to their global operations. The reporting parent entity must submit the information to the ATO in an approved form. The information is subsequently published on an Australian Government website and made publicly accessible.
Entities subject to the reporting requirement
An entity must report for a reporting period if it satisfies all of the following conditions:
The entity is a CbC reporting parent for the preceding period.
The entity is a constitutional corporation, a trust where each trustee is a constitutional corporation, or a partnership where each partner is a constitutional corporation.
The entity was a member of a CbC reporting group at any time during the reporting period.
During the reporting period, the entity or a member of its CbC reporting group was either an Australian resident or a foreign resident operating an Australian permanent establishment.
At least AUD 10 million of the group’s aggregated turnover for the reporting period was Australian-sourced.
The entity is not an exempt entity and is not included in a class of exempt entities.
An entity is considered a CbC reporting parent where it is not controlled by another member of the CbC reporting group and the group’s annual global income is AUD 1 billion or more.
Reporting period and filing deadline
The public CbC reporting regime applies to reporting periods starting on or after July 1, 2024. A reporting parent entity must submit the public CbC report within 12 months after the end of the relevant reporting period. For example, where a reporting period ends on June 30, 2025, the report must be submitted by June 30, 2026.
Information required to be disclosed
The report must include jurisdiction-level information relating to the multinational group’s financial and tax position. Required disclosures include:
Revenue from unrelated parties and related parties
Profit or loss before income tax
Income tax paid on a cash basis
Income tax accrued for the current year
Number of employees on a full-time equivalent basis
Book value of tangible assets excluding cash and cash equivalents
Description of the group’s main business activities
The currency used for the reported information
The report must also include an explanation where income tax accrued differs from the tax amount calculated by applying the applicable statutory corporate income tax rate to profit before tax.
Approach to tax disclosure
The public CbC report must include a statement describing the reporting group’s approach to taxation. This disclosure is intended to provide information on the group’s tax strategy and governance framework relating to tax matters.
Jurisdictional reporting and aggregation
For Australia and jurisdictions specified by legislative instrument, the information must be disclosed on a jurisdiction-by-jurisdiction basis.
For other jurisdictions, the reporting parent entity may disclose the required information either on a jurisdiction-by-jurisdiction basis or in aggregated form.
Submission format and publication
The reporting parent entity must submit the public CbC report to the ATO in an approved electronic format. The ATO facilitates publication of the reported information on an Australian Government website, making the information publicly accessible.
Correction of reported information
If a reporting parent entity identifies a material error in a submitted report, a corrected report must be provided to the ATO within 28 days after the entity becomes aware of the error.
Considerations for U.S. Multinational Enterprises
U.S.-headquartered multinational enterprise groups with operations in Australia may fall within the scope of Australia’s public country-by-country reporting regime, as the revenue threshold (AUD 10 million) is relatively low compared with similar transparency frameworks in other jurisdictions.
Multinational enterprises may therefore wish to consider that the public disclosure of jurisdiction-level financial information could increase transparency and expectations regarding how business activities and financial outcomes are explained across jurisdictions.
Source
Australian Taxation Office, Public country-by-country (CbC) reporting
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Disclaimer:
This content is for general informational purposes only and does not constitute professional advice.
Information provided herein is based on publicly available sources as of the publication date and may be subject to change.
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