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  • Administrative matters

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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 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 global parent entity 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. We will automatically grant you a replacement reporting period 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 global parent entity'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 global 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

    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 statement using a replacement reporting period is 12 months from the end of that period.

    Example 1: Replacement reporting period

    A local entity’s income year ends on 30 June and its foreign parent entity's fiscal year ends on 31 December. The local entity wishes to rely on a CbC report and master file prepared using the foreign parent's fiscal year. A CbC report and master file prepared for the year ending 31 December 2018 will be accepted as replacement reporting for the local entity’s obligations for the year ending 30 June 2019. These statements must be lodged by 31 December 2019.

    Example 2: 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 2019, the replacement reporting period would be the year ending 31 March 2019. Lodgment is due by 31 March 2020.

    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 SGE 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). In the course of lodging CbC reporting statements you will also notify whether you are a global parent entity and, if not, you will disclose the identity of your global parent entity and its jurisdiction.

    You will also have the option to notify that you are doing so 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 The ATO 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 (30 June or substituted accounting period) to which the statements relate. 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 Example 1, the CbC report and master file are due 31 December 2019 and the local file is due 30 June 2020.

    You may request an extension of time to lodge one or more CbC reporting statements. Entities can do so by email to outlining your 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 15 months of the end of the income year.

    Penalties for late lodgment

    Penalties apply for 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 TAA 1953.

    Access to CbC statements

    To the extent that a CbC 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.

      Last modified: 23 May 2019QC 54484