Public CBC report instructions summary
These instructions will help you complete your Public CBC (Public country-by-country) report if you are a Public CBC reporting parent, 'reporting entity' who must publish a report for reporting periods from 1 July 2024 under the Public CBC reporting regime. References in this instruction are to 'you' as the 'reporting entity'.
You must complete the form in English, using the provided XML Schema. These instructions should be used alongside the XML Schema, XML Message Structure Table, and Business Implementation Guide that can be found at Public Country-by-Country reporting 2025 specification v2.0External Link.
A Public CBC report consists of the following 4 sections:
- Section A – include details of the type of report and the reporting entity
- Section B – identify each member entity ('member') of the Public CBC reporting group, by its jurisdiction of residence. The Statement on approach to tax of the Public CBC reporting group is also included in this section
- Section C – include information to be published on a country-by-country (CBC) basis for Australia and each specified jurisdiction (as determined by the Minister). Further detail on reporting requirements and the specified jurisdiction list is available at Information disclosed in the Public CBC report based on jurisdiction. You may also choose to report on a CBC basis for all non-specified jurisdictions – if you choose to, include it here.
- Section D – include the aggregated information to be published for members of the Public CBC reporting group not included in Section C. If you choose to publish on a CBC basis for all non-specified jurisdictions, you should not complete this section – you only need to complete Section C.
Note: Public CBC reporting and CBC reporting are separate measures with different reporting requirements. You and other members of your Public CBC reporting group may be required to complete both reports. For information about CBC reporting, go to Country-by-country reporting.
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 Public CBC.
The words of the law should be applied first after which regard may be had to the aforementioned additional guidance. 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 include in your Public CBC report must reconcile with your audited consolidated financial statements that you, being the reporting entity, prepared for the relevant accounting period in accordance with the applicable accounting standards. Where you do not prepare audited consolidated financial statements, you must publish the information based on amounts that reconcile with what would be shown in such statements, had you been a listed company within the meaning of section 26BC of the Income Tax Assessment Act 1936 (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 reported at a more granular level than what is reported in the consolidated financial statement – for example, the sum of all the Public CBC reported information for separate jurisdictions equals the total amount reported in your 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, for example details of related party transactions.
Residency for tax purposes of a company, partnership, trustee
In the context of a Public CBC report, tax jurisdictions are identified according to where the entities are resident for tax purposes, as recorded in the organisation’s audited consolidated financial statements, or the financial information filed on public record. These entities include dormant entities. See GRI 207-4: Country-by-country reporting.
Australian residency of a company
A company is a resident of Australia for tax purposes if it is either incorporated in Australia, or not incorporated in Australia, but carrying 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.
Australian residency of a partnership
An ordinary partnership does not generally have a separate tax residency status for Australian tax purposes, as it is treated as a tax transparent entity.
For Public CBC reporting purposes, all items referable to a partnership (including income, expenses and assets) may be presented on a single, partnership-level basis. There is no requirement, solely for reporting purposes, to further split, apportion or allocate such items across multiple jurisdictions, or to treat the partnership in whole or part as stateless.
The jurisdictional attribution of the partnership and its items should follow the tax residency of the partners. Where there are partners resident in more than one jurisdiction, a reasonable and consistent allocation methodology should be applied to determine the partnership's residency for Public CBC reporting purposes. Acceptable approaches may include:
- allocating to the jurisdiction in which the majority of partners (by tax residence) are resident; or
- allocating to the jurisdiction to which the substantial proportion of the partnership’s economic activity or revenue is attributable.
This reporting approach does not affect the underlying tax treatment of the partnership. In particular, it does not alter the allocation of income, expenses or other tax attributes to partners, nor the application of source rules or jurisdictional taxing rights, which continue to operate in accordance with relevant tax law.
The residency rules for a company applies to corporate limited partnerships.
Australian residency of a trust
A trust is taken to be a resident of Australia for tax purposes if either at least one of its trustees is an Australian resident, or the central management and control of the trust estate is in Australia.
Residency in other jurisdictions
This approach to determining residency of companies, partnerships and trusts should also be applied for the purpose of determining whether entities are residents of other jurisdictions where required.
Permanent establishments
A permanent establishment is a place at or through which a person carries on any business. For further information on permanent establishments, see subsection 6(1) ITAA 1936, and Taxation Ruling TR 2002/5 Income tax: Permanent establishment – What is 'a place at or through which [a] person carries on any business' in the definition of permanent establishment in subsection 6(1) of the Income Tax Assessment Act 1936?
In the context of a Public CBC report, a permanent establishment is treated as if it itself was a separate entity to the entity of which it is a part of. The permanent establishment is taken to have its location of operation as its tax jurisdiction provided that it prepares a separate financial statement for financial reporting, regulatory, tax reporting, or internal management control purposes. The remainder of the entity of which it is a part would then separately report in its home jurisdiction.
The Public CBC report must be given in the approved form
You, as the Public CBC reporting entity, should register for Public CBC reporting at least 4 weeks before publishing your Public CBC report in the approved form. You can complete registration by following the process outlined at Registration by Public CBC reporting parents. Registration ensures your publishing process runs smoothly.
The requirement to publish a Public CBC report is satisfied by you giving to the Commissioner of Taxation electronically the information required in the designated form ('approved form'), completing that form in accordance with these instructions and us making the report available, in an unamended form, on data.gov.auExternal Link, an Australian government website.
The approved form is an XML file that conforms to the Public CBC XML Schema. The Public CBC report must be sent as an unencrypted XML file via email to PublicCBCReports@ato.gov.au or as otherwise specified by us in writing to you.
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.
When providing information in free text fields, ensure the information provided:
- at a particular field is complete, and
- does not include incorrectly formatted information or information that extends beyond the scope of the question asked.
Your Public CBC report must be provided in the approved form as outlined in these instructions.
If you have been granted a full or partial exemption, or you are part of a class of entities the Commissioner has determined is exempt, you must only provide the information required for your circumstances.
Providing information that is exempt or failing to provide required information, means that your Public CBC report has not been completed in the approved form or in accordance with the instructions. In these cases, we cannot make your Public CBC report available on data.gov.auExternal Link.
Similarly, if you submit information in a different format, through alternative channels, or describe information in a way that does not align to these instructions, we cannot make your Public CBC report available on data.gov.auExternal Link.
If we are unable to make your Public CBC report available on data.gov.auExternal Link, we will contact you by email and ask you to re-submit your report in the approved form and with the correct information.
Note: Your obligation to publish a Public CBC report for the reporting period is only satisfied once you have given us a correct report, in the approved form, that is complete and suitable for publication, such that we can make it publicly available on data.gov.auExternal Link.
Requirement to give a Public CBC report to us
You must publish a Public CBC report if you are a reporting entity. The Public CBC report is due within 12 months after the end of the relevant reporting period. For example, the due dates for publishing a Public CBC report to the Commissioner for reporting period end dates are as follows:
- for the reporting period ending 30 June, the Public CBC report is due on 30 June the following year
- for the reporting period ending 31 December, the Public CBC report is due on 31 December the following year
- for the reporting period ending 31 March, the Public CBC report is due on 31 March the following year.
If you believe you may qualify for an exemption for a reporting period, you must apply for the exemption in a timely manner to allow sufficient time for the Commissioner to consider and decide the application before the Public CBC report due date. An exemption only applies to the reporting period for which it is granted.
To apply for an exemption refer to Public CBC reporting exemptions and Public CBC reporting exemptions and PS LA 2025/2, Public country-by-country reporting exemptions which provides information on eligibility criteria and the process for requesting an exemption.
You will only be exempt from publishing a partial or full Public CBC report once we have assessed your application and notified you in writing of the exemption that has been granted for that reporting period.
If you believe you may qualify for a Government Related Entity (GRE) exclusion from Public CBC reporting for one or more periods, you must apply for the GRE exclusion in a timely manner to allow sufficient time for the Commissioner to consider and decide the application before the Public CBC report due date. A GRE exclusion applies to the reporting period or periods for which it is granted.
For information on eligibility criteria and the process for requesting an exclusion, see Public CBC reporting exclusions for Australian government-related entities.
Failure to comply with your Public CBC reporting obligations can result in penalties. Under section 288-140 of the Taxation Administration Act 1953 (TAA), an administrative penalty may apply if you do not publish the information within 12 months after the end of the relevant reporting period.
Civil penalties may also apply under section 8E of the TAA if you commit an offence under section 8C by failing to comply with your obligations to publish the selected tax information.
Publishing the information
Once a Public CBC report is given to us, we will validate that the information provided aligns with your reporting obligations, considering any full or partial exemption that has been granted to you, or class exemptions that may apply to your circumstance for that reporting period. After we have successfully validated your Public CBC report, including verifying the Public CBC report is in the approved form and has all of the correct information required, we will then make the report available, in its unamended form, on data.gov.auExternal Link.
If we cannot validate your report, we will ask you to re-submit the correct report, noting your obligation to publish a Public CBC report for the reporting period is only satisfied once you have given us a correct report, in the approved form, that is complete and suitable for publication, such that we can make it publicly available on data.gov.auExternal Link.
The information we make available on data.gov.auExternal Link will consist of the global parent name and jurisdiction, the jurisdiction‑level information for member entities in Australia and specified jurisdictions (including your statement on approach to tax), and the required aggregated information for entities in all other jurisdictions. For further information on the data published, see Publishing your Public CBC report.
Continue to: Section A: Public CBC report – entity information.