Australia has introduced new Public Country-by-Country (CbC) reporting requirements that will significantly expand the amount of tax and financial information publicly disclosed by large multinational enterprise (MNE) groups.
Certain multinational groups will be required to lodge a public version of their Country-by-Country report with the Australian Taxation Office (ATO), which will then be published on a public Australian Government website for income years commencing on or after 1st July 2024.
These changes go well beyond existing international standards and place Australia at the forefront of global tax transparency initiatives.
What is required for large multinational groups?
Under this new regime, large multinational groups that already prepare Country-by-Country reports will have additional public disclosure obligations where the group’s Australian-sourced aggregated turnover is more than $10 million.
Disclosures required by the company, and disclosed by the ATO publicly include:
- Statement on approach to tax (new requirement, further details below).
- Name of reporting entities in the CbC reporting group.
- Name of Jurisdiction.
- Description of main business activities.
- Number of employees.
- Revenue from (unrelated) third parties.
- Revenue from related parties.
- Book value of tangible assets.
- Profit/loss before tax.
- Income tax paid (cash basis).
- Income tax accrued (current year).
- Reasons for difference between income tax accrued (current year) and income tax due.
- Currency used for report.
Statement on approach to tax guidelines
An organisation’s approach to tax defines how it balances tax compliance with business activities and ethical, societal, and sustainable development-related expectations. It can include tax principles, attitude to tax planning, the degree of risk willing to be accepted, and the approach to engaging with tax authorities.
A “Statement on approach to tax” is often described in a tax strategy, but it could also be described in equivalent documents, such as policies, standards, principles, or codes of conduct.
The new requirements required by CbC reporting organisations, should outline a description of the approach to tax, including:
- Whether you have a tax strategy and, if so, a link to this strategy if publicly available.
- The governance body or executive-level position within the organisation that formally reviews and approves the tax strategy, and the frequency of this review.
- The approach to regulatory compliance.
- How the approach to tax is linked to the business and sustainable development strategies.
When do the changes apply?
The new Public CbC reporting requirements apply for income years commencing on or after 1 July 2024 (i.e. year ending 30 June 2025). This means:
- For groups with a 31 December year-end, the first public CbC reporting period will apply to the year ending 31 December 2025.
- For groups with a 31 March year-end, the first reporting period will apply to the 31 March 2026.
How does this impact businesses?
The introduction of Public CbC reporting has implications well beyond compliance.
Affected groups should consider:
- Reputational risk: Tax and financial data will be publicly accessible and may be reviewed by media, investors, customers and other stakeholders.
- Consistency of messaging: Public disclosures should align with broader tax governance, ESG and corporate responsibility narratives.
- Data readiness: Systems and processes must support accurate, consistent and defensible reporting across jurisdictions.
- Governance and review: Greater scrutiny increases the importance of robust internal controls and review processes prior to lodgement.
- Global parent entities are encouraged to register with the ATO to enable authorised representatives, including local advisers or Australian subsidiaries, to assist with the preparation and lodgement of Public CbC reports.
How Moore can help
Public Country-by-Country reporting represents a significant shift in Australia’s tax transparency landscape. Our specialists can assist multinational groups to:
- Assess whether you are within scope of the new rules.
- Review existing CbC data and identify gaps against public disclosure requirements.
- Develop and refine statements outlining your approach to tax.
- Manage reputational and governance considerations.
- Support ATO registration and ongoing compliance.
If you would like to understand how these changes affect your group, please contact our Moore Australia Transfer Pricing advisors.
