Legislation implementing Australian public country-by-country (CbC) reporting, for reporting periods that start on or after 1 July 2024 was passed by the Australian Parliament on 29 November 2024. The legislation awaits Royal Assent.
The bill was originally introduced to parliament in June 2024. The Senate Economics Legislation Committee handed down its report in August, recommending that the bill be passed without amendments. The schedule to the bill that includes the CbC reporting rules was not amended.
The 'specified jurisdiction' list, for which disaggregated country level CbC reporting is required, is still to be registered, which should occur after Royal Assent. We expect this to take place in December 2024.
Key highlights of the tax transparency measure
This tax transparency measure will significantly enhance the tax information that multinational groups will need to disclose to the public – affecting not only Australian headquartered multinational (MNE) groups but also foreign owned MNE groups with Australian operations over a certain size.
The Australian rules are broadly based on the narrative and quantitative reporting aspects of Global Reporting Initiatives' (GRI) Sustainability Reporting Standards, in particular GRI 207-1 and 207-4.
Under these rules, in-scope groups will generally be required to provide the following information to the Australian Commissioner of Taxation (Commissioner):
- names of each entity in the CbC reporting group; and
- description of the CbC reporting group's approach to tax.
Quantitative tax information for the income year shown (outlined in the table summary below) for the relevant jurisdictions in which the CbC reporting group operates. The information may be required to be aggregated or disaggregated for disclosure purposes (discussed further below).
This information will be made publicly available on an Australian Government website.
The rules require submission of the select tax information within 12 months of the end of the reporting period.
An important aspect of the measure is that disaggregated country level reporting is required for specified jurisdictions, with the list implemented by way of a determination/legislative instrument (discussed below).
For more detail on the legislation, please visit KPMG Tax Now.
