Australia: Guidance on transitional CbC reporting safe harbor under Pillar Two rules
Updated webpage helps taxpayers determine whether the CbC reporting safe harbor applies
The Australian Taxation Office (ATO) has updated its webpage on the Pillar Two global and domestic minimum tax with new guidance to help taxpayers determine whether the transitional country-by-country (CbC) reporting safe harbor applies.
According to the ATO release (October 22, 2025), the guidance includes an overview of the transitional CbC reporting safe harbor, which includes:
- Conditions for access
- Effects of applying the safe harbor
- The transition period it applies to
In addition, the guidance covers how to apply the three transitional CbC reporting safe harbor tests: