Public country-by-country (CBC) reporting

Check how some large multinational enterprises report tax information to the public on a country-by-country (CBC) basis.

Last updated 2 July 2025

WARNING!

Public CBC reporting and country-by-country (CBC) reporting are different measures. For information about CBC reporting, go to Country-by-country reporting

What is Public CBC reporting

Public country-by-country (CBC) reporting is a regime (the regime) that requires certain large multinational enterprises to publish selected tax information to the public. This information must be reported either on a CBC basis or on an aggregated basis. Under the regime, the parent entity generally has the reporting obligation, rather than the Australian subsidiary (Public CBC reporting parent).

The regime applies for reporting periods starting from 1 July 2024. For a Public CBC reporting parent with a reporting period end of 30 June, this will be from 1 July 2024. Reports are due within 12 months of the end of the reporting period.

If a Public CBC reporting parent has a reporting period that doesn't end on 30 June, the regime will first apply from the start of the relevant period that occurs after 1 July 2024. For example, if a Public CBC reporting parent's reporting period is from 1 April to 31 March, the regime will first apply for its reporting period starting 1 April 2025, with the first report due before 31 March 2027.

The Public CBC reporting parent publishes their Public CBC report by providing selected tax information to the ATO in the approved form. We then facilitate the publication of the information on an Australian Government website.

Public CBC reporting provides information to the public and enables better assessment of whether an entity's economic presence in a jurisdiction aligns with the amount of tax they pay in that jurisdiction.

Public CBC reporting requires disclosures about:

the revenues, profits and income taxes of the global group
the activities of the global group
an entity's international related party dealings.

Note: Public CBC reporting and country-by-country (CBC) reporting are different measures. For information about CBC reporting, go to Country-by-country reporting.

Who is required to report

An entity must report for a reporting period if all of the following apply:

it is a CBC reporting parent for the preceding period
it is an entity of the type specified
it satisfies the requirements for that reporting period.

An entity is of the specified type if it is any one of the following:

constitutional corporation
trust, provided each of the trustees is a constitutional corporation
partnership, provided each of the partners is a constitutional corporation.

'Constitutional corporation' means a foreign corporation (one not formed within Australia), or a trading or financial corporation formed within the limits of the Commonwealth.

An entity satisfies the requirements for a reporting period if all of the following apply:

it was a CBC reporting parent for a period that includes the whole or a part of the preceding reporting period
it was a member of a CBC reporting group at any time during the reporting period
at any point during the reporting period, it, or a member of its CBC reporting group, was an Australian resident or a foreign resident operating an Australian permanent establishment
$10 million or more of its aggregated turnover for the reporting period was Australian-sourced
it wasn't an exempt entity or included in a class of exempt entities.

An entity is a CBC reporting parent for a reporting period if all of the following apply:

it is not an individual
if it is a member of a CBC reporting group at the end of the period; it is not controlled by any other member of the CBC reporting group at the end of the period
its annual global income for the period is $1 billion or more.

Registration by Public CBC reporting parents

Registration by Public CBC reporting parents allows for more efficient processing and helps to simplify the process of:

giving the Public CBC report to the ATO
requesting an extension of time to provide the Public CBC report
requesting an exemption from reporting obligations for a reporting period.

The registration process doesn't differentiate between resident and non-resident Public CBC reporting parents. A non-resident Public CBC reporting parent without an ATO reference number (ARN) will be automatically issued with an ARN as part of this registration process.

Registration is also beneficial as it enables a Public CBC reporting parent entity to provide authorisation for representatives to act on its behalf. This includes having representatives satisfy its obligations, such as lodging the Public CBC report or applying for a Public CBC reporting exemption. Representatives can include:

designated officers or employees of the CBC reporting parent
an authorised representative of the Australian subsidiary
an adviser
other nominated person.

The Public CBC registration form is in a fillable portable document format (PDF), to register you should:

complete the form as per the instructions
use the draw or add image function to add a signature
save the original fillable PDF and submit it via email, don't print and scan it.

Upon lodgment, we will send an email acknowledging receipt.

To get the form, see Public country-by-country (CBC) registration form (NAT 75645). You can also read the Instructions to complete Public country-by-country registration.

Public CBC reporting obligations

The reporting obligation is on the Public CBC reporting parent (whether located overseas or in Australia) to report selected tax information to us.

An Australian subsidiary of a foreign entity generally doesn't have any reporting obligation of its own for a reporting period. An exception to that general principle is if a foreign entity doesn't include the Australian subsidiary in its group’s consolidated accounts, and the Australia subsidiary qualifies as a Public CBC parent entity in its own right.

The Public CBC reporting parent entity must give the Public CBC report electronically in the approved form to the ATO within 12 months after the end of the relevant reporting period.

An update to correct any material errors must be given to us within 28 days of the Public CBC reporting parent identifying or otherwise becoming aware of that error.

Penalties apply for non-compliance.

What is jurisdictional reporting

For Australia and specified jurisdictions determined by the Minister, particular information must be published on a CBC basis.

For operations in other jurisdictions, the Public CBC reporting parent has the choice to publish information on either a CBC basis or an aggregated basis.

Specified jurisdictions list

The Minister's determination of jurisdictions for Public CBC reporting is provided by legislative instrument. The specified jurisdictions are outlined in the Taxation Administration (Country by Country Reporting Jurisdictions) Determination 2024External Link.

Specified jurisdictions

Specified jurisdictions that have a comprehensive international tax agreement with Australia:

Singapore
Switzerland.

Other specified jurisdictions

The following is a list of other specified jurisdictions:

Andorra
Anguilla
Antigua and Barbuda
Aruba
Barbados
Bahamas
Bahrain
Belize
Bermuda
British Virgin Islands
Cayman Islands
Cook Islands
Curacao
Dominica
Gibraltar
Grenada
Guernsey
Hong Kong
Isle of Man
Jersey
Liberia
Mauritius
Monaco
Montserrat
Nauru
Niue
Panama
Republic of the Marshall Islands
Saint Kitts and Nevis
Saint Lucia
Saint Maarten (Dutch Part)
Saint Vincent & the Grenadines
Samoa
San Marino
Seychelles
Turks and Caicos Islands
US Virgin Islands
Vanuatu.

Public CBC information to be reported

The Public CBC reporting parent is required to publish the following information:

its own legal name
the names of each entity in the CBC reporting group
a description of the CBC reporting group’s approach to tax
information about Australia and specified jurisdictions, on a CBC basis
information about its other jurisdictions, either on a CBC or aggregated basis.

Information required to be reported

If the Public CBC reporting parent chooses to report on a CBC basis for all jurisdictions in which the group operates, it doesn't need to publish any information on an aggregated basis.

However, if the Public CBC reporting parent only publishes information on a CBC basis for Australia and the specified jurisdictions, it must publish information for all other jurisdictions on an aggregated basis.

Australia and specified jurisdictions

The Public CBC reporting parent is required to report the following information for Australia and specified jurisdictions:

name of the jurisdiction
description of main business activities
number of employees (on a full-time equivalent basis) at the end of the reporting period
revenue from unrelated parties
revenue from related parties that are not tax residents of the jurisdiction
profit or loss before income tax
book value at the end of the reporting period of tangible assets, other than cash and cash equivalents
income tax paid (on a cash basis)
income tax accrued (current year)
reasons for the difference between income tax accrued (current year) and the amount of income tax due if the income tax rate applicable to the jurisdiction were applied to profit and loss before income tax
currency used in calculating and presenting the above information.

Other jurisdictions (aggregated information)

The Public CBC reporting parent is required to report the following information on an aggregated basis for all other jurisdictions in which the group operates:

description of main business activities in those jurisdictions
number of employees (on a full-time equivalent basis) at the end of the reporting period
revenue from unrelated parties
revenue from related parties that are not tax residents of the jurisdiction in which that revenue is being derived
profit or loss before income tax
book value at the end of the reporting period of tangible assets, other than cash and cash equivalents
income tax paid (on a cash basis)
income tax accrued (current year)
the currency used in calculating and presenting the above information.

Guidance

The information required to be reported has been adopted from the Global Reporting Initiative (GRI) 207: Tax 2019 (GRI 207) reporting standard. The GRI 207 may be used as a source of guidance in interpretating the publishing requirements. Greater detail on the interpretation of terms is contained in the BEPS Action 13 Guidance and OECD Transfer Pricing Guidelines.

For more information see:

Publishing the information

The Public CBC reporting parent is required to publish the information on an Australian Government website by giving the information in the approved form to the ATO. The approved form is in XML Schema format, and lodgment is via email. Upon lodgment, we will send an email acknowledging receipt.

Instructions on the approved form are currently under development and will be available in the second half of 2025.

The ATO's role

We will facilitate the publication of the reported information as soon as practicable on the Australian Government website.

The first publication is expected to be released in late 2026.

Extension of time to provide the Public CBC report

The Public CBC report is due within 12 months after the end of the relevant reporting period. For example, for the reporting period ending 30 June 2025, the Public CBC report is due by 30 June 2026.

A Public CBC reporting parent may apply to the ATO for an extension of time to provide the Public CBC report. The Public CBC reporting parent can submit their request for deferral via email.

Correcting errors

If a Public CBC reporting parent becomes aware of a material error in any of the published information, they must rectify the error by providing the corrected information to the ATO. The entity must provide the corrected Public CBC report in its entirety to us by email.

A correction of a material error is required within 28 days after the entity becomes aware of the error. For example, we will consider an entity aware of a material error once its accountant or tax manager realises the error and prepares an amendment to the entity's income tax return, necessitating an amendment to its Public CBC report.

For a non-material error, the entity may choose to rectify the error by providing the corrected Public CBC report in its entirety to us by email.

If a material or non-material error is rectified by the Public CBC reporting parent, we will publish the corrected information on the Australian Government website as soon as practicable. 

Penalties apply for non-compliance.

Exemptions to Public CBC reporting

The purpose of the Public CBC reporting regime is to enhance tax transparency. However, a Public CBC reporting parent may seek an exemption from reporting obligations. The Commissioner has the discretion, for a single reporting period, to grant an entity a:

full exemption, or
partial exemption specifying that it is exempt from publishing information of a particular kind.

PS LA 2025/D1 provides guidance to staff about exercising the Commissioner’s discretion to grant an exemption from Public CBC reporting obligations. This includes guidance on how we will administer the exemption and the information we expect entities to provide with their exemption application. The Draft PS LA is open for consultation until 5 September 2025.

How to apply for a Public CBC reporting exemption

To apply for a full or partial exemption, you can email your completed application to PublicCBCExemption@ato.gov.au. You can also request a blank copy of the Public CBC reporting exemption application form via the same email address.

If your exemption request relates to national security, we are developing systems and processes for handling these requests and we encourage you to contact us before lodging.

Your exemption request should:

specify the information and jurisdiction for which an exemption is sought
explain the reasons that apply
provide relevant supporting information and documentation, and
confirm authorisation to submit the request and engage with us on behalf of the applicant.

Where your request doesn't provide sufficient information or documentation, we will request this and discuss any concerns with you.

To help us to consider your application, we suggest you include the following:

if requesting a full exemption, the reasons why a partial exemption would not be sufficient
explain what is unusual or exceptional about your circumstances to justify an exemption
detail any link between the specific disclosure or disclosures for which an exemption is requested and any harm or adverse consequences that might be caused by public disclosure
explain why the delay in publication of information under the Public CBC regime doesn't sufficiently reduce the potential harm or consequences that might be caused by public disclosure
explain if aggregation of the information is available, why that aggregation doesn't sufficiently reduce the harm or consequence of disclosure, and
why the information for which the exemption is requested is not and isn't expected to become publicly available in full or part through other reporting obligations or channels.

You can find more detailed guidance in PS LA 2025/D1.

We will engage with you before reaching a decision regarding your exemption application.

Government-related entities

Government-related entities may be relieved from the Public CBC reporting regime under a specific exclusion.

The following are government-related entities:

a department of the State of the Commonwealth
a Department of the Australian Parliament established under the Parliamentary Services Act 1999
an executive agency or statutory agency, within the meaning of the Public Service Act 1999
a department of state of a state or territory
a local government body established by or under a state or territory law
an organisation that satisfies all of the following
- is either established by the Commonwealth, a state or territory (whether under a law or not) to carry on an enterprise or established for a public purpose by an Australian law, and
- can be separately identified by reference to the nature of the activities carried on through the organisation or the location of the organisation

A government-related entity that is a Public CBC reporting entity can be relieved from the regime for one or more reporting periods by written notice from the Commissioner.

Government-related entities can request an exclusion from reporting obligations by emailing PublicCBCExemption@ato.gov.au to get the Public CBC exemption application form. Your request should confirm that you are a government-related entity and provide supporting information.

We will provide further guidance for government-related entities in late 2025.

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