Australia’s ATO has updated its Country-by-Country (CbC) reporting guidance, covering lodgment deadlines, extension requests, local file options, penalties, international exchange obligations, and information disclosure rules.
The Australian Taxation Office (ATO) has released new guidance on 25 September 2026 on administrative matters related to Country-by-Country (CbC) reporting. The updates clarify lodgment deadlines, extension procedures, and international obligations that entities must follow.
Lodgment deadlines
CbC reporting statements must be lodged within 12 months after the income year ends. The income year ends on either 30 June or the balance date of an approved substituted accounting period.
When a replacement reporting period has been approved for one or more statements, the lodgment deadline shifts to 12 months after the replacement period ends. For example, if a CBC report and master file are due 31 December 2022, the local file becomes due 30 June 2023.
Extension requests and the NAT 75845 form
Entities that cannot meet the standard deadline may request an extension of time to lodge one or more CbC reporting statements. The ATO requires entities to complete the Country-by-Country Request form (NAT 75845) and provide details about the circumstances and reasons for the extension request.
International exchange obligations
The ATO has emphasised that extension requests must account for international exchange obligations. CbC reports are automatically exchanged with other jurisdictions within three months of the initial lodgment due date. This means late extensions cannot push lodgment beyond this critical window if automatic exchange is required.
Entities managing multiple jurisdictions or complex group structures should plan submissions carefully to meet both domestic deadlines and international reporting timelines.
Local file administration options
Reporting entities may choose to lodge Part A of their local file at the same time as their tax return or through an ATO approved lodgment concession. Entities selecting this option will not need to complete the relevant IRPD labels in Questions 2 to 17 of the IDS.
Part B of the local file must be lodged by the statutory due date regardless of when Part A is submitted. Entities requesting this alternative arrangement must lodge Part A by the tax return due date. Any further delay requires a separate extension request for the tax return itself.
The ATO does not require re-submission of agreements already provided in previous communications. Part B includes a notification field for indicating when an agreement has been previously provided to the ATO.
Late lodgment penalties
Significant Global Entity (SGE) penalties may apply for late lodgment of CbC reporting statements. Each statement (CBC report, master file, and local file) is treated as a separate statement for penalty purposes. The penalty amount, including any multiplying factor, is calculated under section 286-80 of Schedule 1 of the Tax Administration Act 1953.
Entities facing late lodgment circumstances, including situations where failure to lodge (FTL) penalties or interest have been imposed, may submit a Country-by-Country Request form (NAT 75845) to request reconsideration. The form must outline the circumstances or events that prevented timely lodgment.
Information access and disclosure
The ATO will generally not disclose information contained in a CbC reporting statement to the Australian entity if that information relates to other entities outside the Australian entity or its Australian tax consolidated group or MEC group.
Earlier, the Australian Taxation Office (ATO) issued guidance on public Country-by-Country (CbC) reporting on 9 June 2026 with reporting rules applying to reporting periods beginning on or after 1 July 2024, with reports generally required to be filed within 12 months after the end of the relevant reporting period.
