Public Country by Country reporting in Australia

Public CbC reporting: what you need to know

Australia has introduced a new public tax transparency regime, Public Country-By-Country (CbC) reporting that requires certain multinational groups (MNE) to publicly disclose tax and financial information. The information will to be published on the Australian government website which is a significant shift from previous disclosures which were confidential.

This regime is separate from (and in addition to) existing confidential OECD CbC reporting and other tax filings. It applies to reporting periods starting on or after 1 July 2024.

The first Australian filings are due by 30 June 2026 (in relation to the year ended 30 June 2025).

This note sets out who is affected, what applies in Australia, and what actions are required now.

Who is required to report?

Public CbC reporting obligations generally applies to MNE groups that:

• Has global consolidated revenue of AUD 1 billion or more, and
• Has Australian‑sourced turnover of at least AUD 10 million, and
• Has operations in Australia (including via an Australian subsidiary or permanent establishment)

This includes foreign‑headed multinational groups with Australian operations (even where the global parent is offshore).

Importantly, the global parent entity (not the Australian subsidiary) is responsible for lodging the Public CbC report.

What information must be disclosed publicly ?

The public disclosures required under the Australian rules are more extensive than the public reporting requirements in some other countries (e.g. in Europe). The report includes financial, tax and operational information using data from the MNE group’s audited consolidated financial statements, as well as certain qualitative disclosures.

For Australia, this includes information relating to:

• Revenue (related and unrelated);
• Profit or loss before tax;
• Income tax expense and income tax paid;
• Number of employees;
• Tangible assets;
• Retained earnings and stated capital.

In addition, groups must disclose:

• A list of group entities and their activities;
• A narrative explanation of the group’s approach to tax; and
• Explanations for material differences between tax expense and headline tax rates.

Some jurisdictions must be shown separately (such as Australia and certain specified jurisdictions), while others may be aggregated.

When are the first reports due?

The Public CbC report will be due within 12 months of the end of the reporting period as follows:

Public CbC reports must be prepared using the ATO‑approved XML format. Reports must be lodged electronically by email (to assist foreign parent entities to lodge from overseas).

Once the public CbC is lodged with the ATO, the publication of the information will be facilitated by the Commissioner and published on Data.gov.au.

Global parent entities are encouraged to register with the ATO to facilitate the lodgment and any exemption requests, as well as if using an authorised tax agent in Australia.

Failure to comply with Public CbC reporting obligations may attract significant penalties under the Significant Global Entity (SGE) framework, with administrative penalties up to AUD 800,000+.

Any material errors identified after publication must be corrected within 28 days, with penalties applying for non‑compliance.

Exemptions and ATO discretion

As noted above, global parent entities are not required to lodge a public CbC report if their aggregated turnover for the income year includes less than a total of AUD 10 million of Australian-sourced income.

In addition, and in limited cases, the ATO may grant full or partial exemptions. The ATO released Practice Statement Law Administration PSLA 2025/2 which provides guidance on public CbC exemptions. Please refer to this guide for more information.

Exemptions are not automatic and must be applied for. The ATO has indicated exemptions will be narrowly granted and only in exceptional circumstances with high expectation of supporting evidence.

Early engagement is strongly recommended if an exemption may be relevant. Key considerations include:

• Whether disclosure would cause disproportionate or irreversible harm;
• Whether aggregation already sufficiently obscures sensitive information;
• Whether the information is already publicly available;
• Whether a partial exemption can preserve transparency while mitigating harm.

There is no self‑assessment exemption, entities must apply formally and receive written confirmation before treating an exemption as granted.

What should affected groups be doing now?

With the 30 June 2026 deadline approaching, groups should:

• Confirm whether they are in scope of Public CbC Reporting;
• Assess eligibility for exemption and if so, begin preparing early;
• Gather and validate required CbC and accounting data;
• Identify data gaps between financial reporting, CbC data and Pillar Two;
• Consider governance and sign‑off processes for public disclosures;
• Engage early to manage risk, consistency and communication strategy.

How PKF can help

We can assist with:

• Public CbC report scoping and impact assessments;
• Registration of the ultimate parent entity with the ATO;
• Preparation and lodgment of Australian public CbC report in XML format;
• ATO engagement and exemption applications;
• Applications for an extension of time to lodge the Public CBC Report.

If you would like to discuss how Public CbC reporting affects your group, or what is required before 30 June 2026, please contact your PKF tax team.