Australia: Draft guidance on granting exemptions to public CbC regime
Comments on draft guidance due September 5, 2025
The Australian Tax Office (ATO) on July 3, 2025, released draft PSLA 2025/D1, providing guidance to ATO staff on granting exemptions to Australia’s public country-by-country (CbC) reporting obligations.
The exemptions may be granted in full or partially at the Commissioner's discretion under “exceptional circumstances” only, and exemptions are granted one reporting period at a time and must reapply in subsequent years, if needed.
The draft PSLA 2025/D1 provides the following examples of matters that would be appropriate to consider for exemptions:
- Impact on national security
- Breach of Australian law
- Breach of the laws of another jurisdiction
- Revealing commercially sensitive information
- Public CbC thresholds in other jurisdictions
Appendix 1 of the draft PSLA 2025/D1 also provides scenarios for each of the above matters to illustrate some of the circumstances that may or may not give rise to a full/ partial exemption.
The ATO has invited comments on the draft PSLA 2025/D1 by September 5, 2025.
For more information, contact a KPMG tax professional in Australia:
Sean Madden | smadden3@kpmg.com.au
Valerie Koo | vkoo1@kpmg.com.au