Instructions summary
These instructions will help you complete your Public CBC report if you are a CBC reporting parent, 'reporting entity' who must publish a report for reporting periods from 1 July 2024 under the Public CBC reporting regime.
The form must be completed in English, using the provided XML Schema. These instructions should be used alongside the XML Schema, Message Structure Table and Business Implementation Guide that can be found at the Public Country-by-Country reporting 2025 specification v1.0External Link.
A Public CBC report consists of 4 sections:
- Section A - include details of the type of report and the reporting entity.
- Section B - identify each member entity ('member') of the CBC reporting group, by its jurisdiction of residence. The 'Statement on approach to tax' of the CBC reporting group is also included in this section.
- Section C - include the information to be published on a CBC basis for Australia and each specified jurisdiction. Further information on jurisdictional reporting that have been determined by the Minister, is available. You may also choose to report on a CBC basis for non-specified jurisdictions.
- Section D - include the aggregated information to be reported for members of the CBC reporting group not included in section C.
Public CBC reporting guidance
The information you must report has been adopted from the Global Reporting Initiative (GRI) 207: Tax 2019External Link (GRI 207) reporting standard. Some terminology differs to ensure consistency with how these concepts are understood in Australia, both under Australian domestic law and Australian accounting standards. For example, the 'disclosure of revenue from unrelated parties' corresponds to GRI 207’s ‘revenue from third party sales’.
The Base Erosion and Profit Shifting (BEPS) Action 13 Guidance and the Organisation for Economic Co-operation and Development (OECD) transfer pricing guidelines provide further contextual guidance having regard to the development of Public CBC.
The words of the law should be applied first. To the extent of any inconsistency or differences in terminology, treat GRI Disclosures 207-1 and 207-4 of GRI 207:Tax 2019 as prevailing over The BEPS Action 13 Guidance and the OECD transfer pricing guidelines.
Compilation requirement
The information you report must be based on information as included in your audited consolidated financial statements prepared in accordance with the applicable accounting standards. Where you have not prepared audited consolidated financial statements, you must publish the information based on amounts that would be shown in such statements for the relevant reporting period, had you been a listed company within the meaning of section 26BC of the ITAA 1936 and been required to prepare them.
The information must either be drawn from consolidated financial statements or from information that can be reconciled to consolidated financial reports.
Information that can be reconciled to consolidated financial reports includes:
- information that is reported is at a more granular level than what is reported in the consolidated financial statement, for example information for jurisdictions is reconciled when the sum of this data for all jurisdictions equals the amount reported in the organisation’s audited consolidated financial statements.
- information in respect of transactions which are eliminated as part of the consolidation process, the information reported aligns with the working papers for the transactions that were eliminated as part of the consolidation process.
Residency for taxation purposes of a company, partnership, and trustee
A company is a resident of Australia for taxation purposes if it is either incorporated in Australia, or not incorporated in Australia but carries on business in Australia and has either its central management and control in Australia, or voting power controlled by shareholders who are residents of Australia. For further information on central management test of corporate residency see Taxation Ruling TR 2018/5 Income tax: central management and control test of residency.
A partnership is a resident of Australia for taxation purposes where there is at least one member that is an Australian resident.
A trust is a resident of Australia for taxation purposes where a trustee of a trust estate is an Australian resident, or the central management and control of the trust estate is in Australia.
The Public CBC report must be given in the approved form
You must publish your Public CBC report by giving it to us in the approved form for publication. The requirement to publish a Public CBC report encompasses you giving the information to us in the approved form and us then publishing it, in an unamended form, on a government website.
You must give us the information in the approved form by ensuring all required information is given to the Commissioner of Taxation electronically in the specified form. The report must be sent as an unencrypted file via email to PublicCBCReports@ato.gov.au. The XML file does not need to be digitally signed. The maximum file size for an individual XML report is 15 MB. If the file exceeds 15 MB, it should be zipped – ensuring the zipped file remains within the 15 MB limit – before being emailed to the ATO. Encrypted files will not be accepted, only files with file extensions *.xml or .zip* will be accepted.
In respect of providing information for free text field labels this includes ensuring both that:
- the information provided at a particular label is complete and
- it does not include information that is incorrectly formatted or extends beyond the scope of the question asked.
Giving us the information in the approved form is important for publishing. Giving us the information by other means or stating it differently would require us to extract that information and process it to translate it into the correct form and format. This is not something that is provided for under the law which governs Public CBC reporting. Hence, we are unable to accept Public CBC reports that are not provided to us in the approved form.
Requirement to give a public CBC report to us
You must give us a Public CBC report if you are a reporting entity.
You are only exempted from publishing a partial or full Public CBC report once we have notified you in writing of the exemption. See Exemptions to Public CBC reporting for further information.
Failure to comply can result in penalties. You are liable to an administrative penalty under section 288-140 of the Taxation Administration Act 1953 (TAA), where you do not publish the information within 12 months after the end of the reporting period to which it relates.
Action may also be taken to apply civil penalties to entities under section 8E of the TAA for committing an offence under section 8C by failing to comply with their obligations to publish the selected tax information.
Continue to: Section A: Public CBC report- entity information