Australia's tax authority issued fresh guidance on public country-by-country reporting on 9 June 2026, covering a regime that applies to periods beginning on or after 1 July 2024, with reports due within 12 months of period end.
The Australian Taxation Office (ATO) issued new guidance on public country-by-country (CbC) reporting on 9 June 2026. Australia’s public CbC reporting rules apply to reporting periods commencing on or after 1 July 2024, with reports required to be filed within 12 months after the end of the relevant reporting period.
The guidance outlines key aspects of the reporting framework, including the following:
Public country-by-country (CBC) reporting is a corporate transparency measure which requires Public CBC reporting parents to publish an annual Public CBC report detailing selected tax information. The process requires you to do so by giving us the necessary information in the approved form, and then us making it available on data.gov.au, 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. The regime applies to reporting periods starting on or after 1 July 2024. It does not apply to individuals.
The reporting obligation for Public CBC rests with the global parent entity, known as the Public CBC reporting parent, whether located overseas or in Australia. An Australian subsidiary of a foreign entity does not generally have its own Public CBC reporting obligation. One exception is where a foreign entity doesn’t include the Australian subsidiary in its group’s consolidated accounts, and the Australian subsidiary qualifies as a Public CBC reporting parent in its own right.
Information disclosed based on jurisdiction
The Public CBC report requires disclosures about:
- the revenues, profits and income taxes of the Public CBC reporting group
- the activities of the Public CBC reporting group
- an entity’s international related party dealings.
Publishing your Public CBC report
Register for Public CBC reporting at least 4 weeks before publishing the first Public CBC report, or if taxpayers intend to apply for an exemption, GRE exclusion, or deferral. Registration helps streamline administration. Taxpayers must publish their Public CBC report by giving the information to the ATO in the approved form within 12 months following the end of their reporting period. The ATO then make it available on data.gov.au. Penalties may apply for non-compliance.
Registration by Public CBC reporting parents
Register at least 4 weeks before the date you intend to engage with us on a Public CBC matter. Registration allows you to manage your obligations more efficiently and helps to simplify the process of:
- publishing your Public CBC report
- requesting an extension of time to provide the Public CBC report
- requesting an exemption from reporting obligations for a reporting period
- requesting a government-related entity (GRE) exclusion from reporting obligations for a reporting period/s
- correcting errors in your Public CBC report after publishing.
The registration process does not 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 issued with an ARN as part of this registration process.
Correcting errors in Public CBC reporting
If an entity becomes aware of a material error in any of the published information, it must correct it. To correct a Public CBC report, the entity must complete the Public CBC report again in the approved form with the correct information and publish it using the same Public CBC reporting submission process. The corrected report will replace the original report published. All fields must be completed in the corrected Public CBC report, including fields that have not been changed.
A correction of a material error is required within 28 days after the entity becomes aware of the error. For example, within 28 days of the accountant or tax manager realising the error and preparing an amendment to the entity’s income tax return, necessitating an amendment to the Public CBC report.
Penalties apply for non-compliance.
Public CBC reporting exemptions
The purpose of Public CBC reporting is to enhance tax transparency, but a Public CBC reporting parent may apply for an exemption. The Commissioner has the discretion, for a single reporting period, to grant a Public CBC reporting parent entity either a:
- full exemption from its reporting obligations, or
- partial exemption, specifying that it is exempt from publishing information of a particular kind.
Practice Statement Law Administration PS LA 2025/2 Public country-by-country reporting exemptions provides guidance to ATO staff about exercising the Commissioner’s discretion to grant an exemption from Public CBC reporting obligations on a case-by-case basis. This includes guidance on how we will administer an application for an exemption and examples of information we expect to be provided to us in support of an exemption application.
If you believe you 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 publishing due date. An exemption only applies to the reporting period for which it is granted.
Exclusions for Australian government-related entities
Government‑related entities (GREs) for Public CBC purposes refers to corporate tax entities controlled or established by the Commonwealth, or a state or territory government of Australia, to perform public or governmental functions. GREs are typically subject to separate public sector accountability and disclosure frameworks.
The GRE concept in this regime is limited to entities established by, or otherwise attributable to, Australian Governments only.
Further guidance on the meaning of a GRE is available in Goods and Services Tax Ruling GSTR 2000/10 Goods and services tax: recipient created tax invoices.
