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  • Country-by-Country reporting guidance

    This document provides guidance on the implementation of Country-by-Country (CbC) reporting in Australia.

    CbC reporting is part of a broader suite of international measures aimed at combating tax avoidance. Subdivision 815-E of the Income Tax Assessment Act 1997 (ITAA 1997) implements the 2015 Final Report of Action 13 of the OECD/G20 Base Erosion and Profit Shifting ProjectExternal Link.

    CbC reporting incorporates revised standards for transfer pricing documentation and a common template for significant global entities (SGEs) to report income and other measures of economic activity for each country in which they conduct their activities.

    The measure balances the need to enhance transparency for these entities with the cost of providing information to tax authorities for assessing the risk of transfer pricing.

    The measure applies to income years commencing on, or after, 1 January 2016. If you were an SGE for the whole or a part of the previous income year and you have a specified connection to Australia, you will be required to provide us with three statements within 12 months after the end of your income tax year. These statements are the:

    • CbC report
    • master file
    • local file.

    The statements require you to report details, by jurisdiction, regarding your global and local operations and activities, transfer pricing policies, international related party dealings, revenues, profits, and taxes paid.

    In most cases, the CbC report will be filed in the jurisdiction of a multinational group’s global parent entity and automatically exchanged with tax authorities in other jurisdictions in which the group operates.

    Australia is one of more than 70 countries (PDF 214KB)External Link that have signed a multilateral agreement (PDF, 406KB)External Link which facilitates automatic exchange of CbC reports between tax authorities in different jurisdictions. In circumstances where you operate in a jurisdiction that is not covered under the multilateral arrangement, exchange can still occur under a bilateral agreement.

    Our guidance

    This guidance outlines our administrative practice, including advice on CbC reporting to assist you in understanding and meeting your obligations under Subdivision 815-E of the ITAA 1997.

    This document supplements and should be read with LCG 2015/3 Subdivision 815-E of the Income Tax Assessment Act 1997: Country-by-Country reporting (issued 17 December 2015).

    The three types of statements required under the CbC reporting regime correspond to the master file, local file and CbC report in Annexes I, II and III to Chapter V of the Final Report. We have approved forms for each of these statements.

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      Last modified: 23 May 2019QC 54484