Australian Taxation Office (ATO) expanded the definition of “significant global entity (SGE)”. The SGE concept determines whether an entity is subject to a number of tax integrity and reporting measures. The SGE concept was introduced by the Tax Laws Amendment (Combating Multinational Avoidance) Act 2015 to define the population subject to the multinational anti-avoidance law (MAAL), country-by-country reporting (CBC reporting) and the entities required to give the Commissioner a general purpose financial statement (GPFS). Subsequently, the SGE concept was used to define entities that may be subject to the diverted profits tax (DPT) and increased administrative and other penalties.

For income years beginning on or after 1 July 2019, an entity is an SGE for a period if it is any of the following:

  • A global parent entity (GPE) with annual global income (AGI) of AU$1 billion or more;
  • A member of a group of entities consolidated for accounting purposes and one of the other group members is a GPE with actual consolidated AGI of AU$1 billion or more;
  • A member of a notional listed company group (NLCG) and one of the other group members is a GPE with notional consolidated AGI of AU$1 billion or more; and
  • A member of an actual or notional accounting consolidated group when the Commissioner has made a determination that there is actual or notional consolidated GPE with AGI of AU$1 billion or more.