The guidance outlines several benefits of voluntary registration.
The Australian Taxation Office (ATO) released additional guidance on its public country-by-country (CbC) regime on 12 June 2025. The guidance outlines several benefits of voluntary registration, which include simplifying public CbC report submissions, nominating an authorised representative, requesting submission extensions, and applying for exemptions from reporting obligations.
The new rules are effective for reporting periods starting on or after 1 July 2024. For a Public CbC reporting parent with a reporting period ending 30 June, the rules will be effective 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 does not 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.
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 any one of the following apply:
- Constitutional corporation
- Trust, provided each of the trustees is a constitutional corporation
- Partnership, provided each of the partners is a constitutional corporation.
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 the 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.
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 does not have any reporting obligation of its own for a reporting period. An exception to that general principle is if a foreign entity does not 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.
