Guidance on administrative matters and CBC reporting.
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Lodgment on behalf of the accounting group
An entity can lodge a master file or a CBC report (including a CBC report notification) on behalf of any other members of the same global accounting group. If the lodging entity identifies the other members of the accounting group to be covered by the lodgment, those other entities will not be required to lodge that master file or CBC report.
Alternatively, an entity lodging a local file can obtain relief from lodging a master file or CBC report by telling us when lodging the local file that a CBC report or master file is being lodged on their behalf by another entity.
Replacement reporting periods
Commonly a CBC reporting parent will prepare a CBC report and master file based on their reporting period. This reporting period could differ from your income year and if so, it may be necessary for you to use a replacement reporting period for those CBC statements. A replacement reporting period automatically applies if you:
- lodge a CBC report, a CBC report notification or a master file (or another entity does so on your behalf) that uses or refers to a reporting period different to your income year
- are using that reporting period because it aligns with your CBC reporting parent's reporting period
- the replacement reporting period ends before the end of the income year that it replaces.
If you meet the conditions above, no separate request is required. The replacement reporting period will apply to both the CBC report and master file, including a CBC report that will be received on exchange from another jurisdiction.
If you want to use a replacement reporting period for reasons other than aligning with your CBC reporting parent entity's reporting period, or are seeking a replacement reporting period for the local file, you will need to make a request by emailing CBCreporting@ato.gov.au.
A replacement reporting period in respect of the local file would only be approved in exceptional circumstances.
The due date for lodgment of a CBC reporting statement using a replacement reporting period is 12 months from the end of that period.
Example: replacement reporting period
A local entity’s income year ends on 30 June 2022 and its foreign parent entity's fiscal year ends on 31 December 2021. The local entity wishes to rely on a CBC report and master file that have been prepared using the foreign parent's fiscal year.
A CBC report and master file prepared for the fiscal year ending 31 December 2021 will be accepted as meeting the local entity’s obligations for their income year ending 30 June 2022. The replacement reporting period for the CBC report and master file would be the year ending 31 December 2021. These statements must be lodged by 31 December 2022.
Example: replacement reporting period
If the local entity’s income year ends on 31 December and the foreign parent entity's fiscal year ends on 31 March, a replacement reporting period is permissible for the CBC report and master file. For the income year ending 31 December 2022, the replacement reporting period would be the year ending 31 March 2022. Lodgment is due by 31 March 2023.
End of example
Under Australian CBC reporting, you do not notify us of the matters contained in Article 3 of the OECD model legislation. If you report in Australia, you will provide notification in your tax return as to your CBC reporting entity status for the income year for which your return is lodged (we acknowledge that this is not conclusive of having CBC reporting obligations, which are determined by your status in the prior year). When lodging CBC reporting statements, you will also notify us as to whether you are a CBC reporting parent and, if you are not, you will disclose the identity of your CBC reporting parent and its jurisdiction of tax residence.
You will also have the option of notifying us as to whether you are lodging a CBC report as a surrogate parent entity, with the lodgment intended to meet a CBC reporting obligation in another jurisdiction. However, some foreign jurisdictions may require the notification to be provided to us earlier than the time of lodging the CBC report.
In such instances, you need to be aware of any timing requirements under foreign CBC laws and provide the notification within the time required by those laws by email to CBCreporting@ato.gov.au. We will accept and record notifications of this nature.
Lodgment and extensions
CBC reporting statements must be lodged within 12 months after the end of the income year to which the statements relate. The end date of the income year will be either 30 June or the balance date of the substituted accounting period. Where a replacement reporting period has been approved for one or more statements, those CBC reporting statements must be lodged within 12 months after the end of the replacement reporting period. In the first example above the CBC report and master file are due 31 December 2022 and the local file is due 30 June 2023.
You may request an extension of time to lodge one or more CBC reporting statements. Entities can do so by emailing CBCreporting@ato.gov.au and outlining their circumstances and reasons for requesting the extension.
In making such a request, entities need to be mindful that we will have regard to international exchange obligations. We are obliged to automatically exchange the CBC report for a group within 3 months of the initial due date for lodgment.
Local file administrative solution
If a reporting entity chooses to voluntarily lodge Part A of their local file at the same time as their tax return (or as per ATO approved lodgment concession), they will not need to complete the relevant IRPD labels in Questions 2 to 17 of the IDS. Part B of the local file must be lodged by the statutory due date.
If you choose this option, you will need to lodge Part A by the time that your tax return is due. If you need more time, you will need to request an extension of time to lodge the tax return.
If the reporting entity has already provided relevant agreements to us, they don't need to provide the agreements to us again through the local file. Part B of the local file includes a provision for notifying us if an agreement has already been provided.
Penalties for late lodgment
SGE penalties may apply for the late lodgment of CBC reporting statements. Each CBC reporting statement (CBC report, master file and local file) is a separate statement for these purposes. The amount, including any multiplying factor, is worked out under section 286–80 of Schedule 1 of the Tax Administration Act 1953.
Access to CBC statements
To the extent that a CBC reporting statement contains information on entities other than the Australian entity or members of its Australian tax consolidated group or MEC group, we will generally not disclose that information to the Australian entity.