Public Country-by-Country (CbC) Reporting Update

The Australian Taxation Office has released administrative details on the new Public CbC reporting obligations that take effect for financial years starting on or after 1 July 2024. These new obligations require groups with more than AUD 1 billion global turnover and AUD 10 million of Australian-sourced turnover to report annually on:

• Legal names of all members of the global group

• The group's approach to tax

• Detailed information: business activities, number of employees, revenue for third-parties, revenue from foreign related parties, EBT, tangible assets' value, income tax paid, income tax accrued

While other countries have commonly been asked to report this information for many years, the Australian reporting requirements will be significantly greater:

• Australia requires not only reporting at the group level (in the aggregate) and at the Australian level, but also separately for each jurisdiction within a specified list, which includes all low/no-tax jurisdictions, as well as Singapore and Switzerland.

• Once reported, the information will become public.

Reporting is due within 12 months of the CbC parent's financial year-end. As with most tax matters affecting Significant Global Entities, penalties for failure to lodge on time are applied at a 500-multiplication factor, currently ranging from AUD 165,000 (for being 1 day late) to AUD 825,000 (for being more than 4 months late).

The new obligations depart from the established Australian Country-by-Country regime, in that they are imposed on the CbC Parent entity, rather than on the Australian entities. This will require additional registration steps prior to submission of the report. Thankfully, this particular registration appears rather straight-forward and does not require proof of identity.

Oceade assists CbC Reporting entities with their compliance requirements. Please let us know if you have any questions, so that we can plan this crucial reporting well in advance.