Public country-by-country (CBC) reporting

Check how some large multinational enterprises report tax information to the public on a country-by-country (CBC) basis.

Last updated 3 March 2026

WARNING!

Public CBC reporting and country-by-country (CBC) reporting are different measures. You and members of your Public CBC reporting group may be required to complete both reports independently. For information about CBC reporting, go to Country-by-country reporting.

What is Public CBC reporting?

Public country-by-country (CBC) reporting requires certain large multinational enterprises to publish an annual Public CBC report to us, which is then uploaded to data.gov.auExternal Link.

Depending on the jurisdiction, the information must be reported either on a CBC basis or in aggregated form. The global parent entity holds the reporting obligation, not the Australian member. This entity is known as the Public CBC reporting parent.

Reporting periods begin on 1 July 2024. For a Public CBC reporting parent with a reporting period end of 30 June, this will be from 1 July 2024. Reports are due within 12 months of the end of the reporting period.

If a Public CBC reporting parent's reporting period doesn't end on 30 June, reporting will apply from the start of the first period beginning after 1 July 2024. For example, a reporting period from 1 April to 31 March will first be subject to reporting from 1 April 2025, with the report due by 31 March 2027.

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.

Public CBC reporting requires disclosures about:

the revenues, profits and income taxes of the global group
the activities of the global group
an entity's international related party dealings.

Note: Public CBC reporting and country-by-country (CBC) are separate measures with different reporting requirements. You and members of your Public CBC reporting group may be required to complete both reports independently. For information about CBC reporting, see Country-by-country reporting.

Who is required to report?

An entity must report for a reporting period if all of the following apply:

it was a Public CBC reporting parent for the preceding period
it is an entity of the type specified
it satisfies the requirements for that reporting period.

An entity is of the specified type if it is any one of the following:

constitutional corporation
trust, provided each of the trustees is a constitutional corporation
partnership, provided each of the partners is a constitutional corporation.

Constitutional corporation means a foreign corporation (one not formed within Australia), or a trading or financial corporation formed within the limits of the Commonwealth.

An entity satisfies the requirements for a reporting period if all of the following apply:

it was a Public CBC reporting parent for a period that includes the whole or a part of the preceding reporting period
it was a member of a Public CBC reporting group at any time during the reporting period
at any point during the reporting period, it, or a member of its Public CBC reporting group, was an Australian resident or a foreign resident operating an Australian permanent establishment
$10 million or more of its aggregated turnover for the reporting period was Australian-sourced
it wasn't an exempt entity or included in a class of exempt entities.

An entity is a Public CBC reporting parent for a reporting period if all of the following apply:

it is not an individual
if it is a member of a Public CBC reporting group at the end of the period; it is not controlled by any other member of the Public CBC reporting group at the end of the period
its annual global income for the period is $1 billion or more.

Registration by Public CBC reporting parents

Registration allows Public CBC reporting parents to manage their obligations more efficiently and helps to simplify the process of:

giving the Public CBC report to us
requesting an extension of time to provide the Public CBC report
requesting an exemption from reporting obligations for a reporting period.

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 automatically issued with an ARN as part of this registration process.

When you register or lodge a Public CBC report, you are asked to provide information about

who we can contact in relation to your Public CBC matters
who is authorised to sign the declaration on behalf of the entity (that is, public officer or authorised contact, or authorised representative ('authorised person')).

The roles are different and serve different purposes. While the same person may be appointed in both roles, this is not required.

Contacts and signatories

The registration form collects contact details for different purposes.

Authorised contacts

Authorised contacts are your nominated representatives for day-to-day communication about administration tasks, including registration, lodgment, and exemption requests. They must have authority to act for you, including making changes or updating information.

you can nominate more than one person (for example, a primary authorised contact and an alternative authorised contact)
if the primary contact cannot be reached, we may contact the alternative (if provided).

Australian member entity contacts

Australian member entity contacts are Australia-based contacts we may approach for more information about the Australian member entity (where Section B of the registration form applies).

Where there is more than one Australian member entity in the Public CBC reporting group, you only need to provide details for the most significant or relevant entity that derived the majority of the group’s Australian‑source income.

Providing these contacts does not change who has the Public CBC reporting obligation, which remains with you as the Public CBC reporting parent.

Authorised tax agent

You may nominate an authorised tax agent to engage with us on your behalf in relation to Public CBC reporting matters.

Australian tax agents must be registered with the Tax Practitioners Board (TPB). You can check a tax agent's registration status or find a registered tax agent through the TPB websiteExternal Link.

Declaration signatory

The declaration signatory is the person who is authorised to sign the declaration on behalf of the registering entity.

The declaration must be signed by a person who is currently recorded by us as having authority to update registration details on behalf of the entity (for example, the public officer or authorised person).

Public officer

Under the Australian tax system, a company's public officer is the person we normally deal with in relation to the entity's tax affairs.

A company that conducts an enterprise in Australia (that is, carries on business in Australia or derives income from property in Australia) is required to be represented for taxation purposes by a public officer.

For guidance on the role of a public officer, refer to Law Administration Practice Statement PS LA 2011/8 The registration of entities.

Overseas Public CBC reporting parents

A Public CBC reporting parent that is based overseas and does not conduct an enterprise in Australia is not required under Australian tax law to have a public officer. We ask that entities appropriately execute documentation, in accordance with the laws of their jurisdiction, to appoint a representative to engage with us on their behalf for Australian Public country-by-country reporting purposes.

The appointed representative may include a person located in Australia.

The entity should retain this documentation as evidence of the representative’s authority, as we may request it to confirm authority where required.

Further information

Further detail on primary contacts (including public officers) and authorised contacts is available at Primary contacts and authorised contacts.

Public CBC registration form

The Public CBC registration form is in a fillable portable document format (PDF). To register:

complete the form as per the instructions
use Adobe Acrobat's Fill & Sign tool to add signature, alternatively use the draw or add image function
save the original fillable PDF and submit it via email to PublicCBCReports@ato.gov.au. Do not print and scan it.

You are encouraged to register at least 4 weeks before the date you intend to engage with us on a Public CBC matter.

Registering doesn't create extra obligations for you but provides a smoother reporting and lodgment process.

Upon lodgment, we will send an email acknowledging receipt.

Get the registration form

Download the form at Public country-by-country (CBC) registration form (NAT 75645).

You can also read the Instructions to complete Public country-by-country registration.

Public CBC reporting obligations

The reporting obligation is on the Public CBC reporting parent (whether located overseas or in Australia) to report selected tax information to us.

An Australian subsidiary of a foreign entity generally doesn't have any reporting obligation of its own for a reporting period. 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 parent in its own right.

The Public CBC reporting parent must give the Public CBC report electronically in the approved form to us within 12 months after the end of the relevant reporting period.

An update to correct any material errors must be given to us within 28 days of the Public CBC reporting parent identifying or otherwise becoming aware of that error.

Penalties apply for non-compliance.

What is jurisdictional reporting?

For Australia and specified jurisdictions determined by the Minister, particular information must be published on a CBC basis.

For operations in other jurisdictions, the Public CBC reporting parent has the choice to publish information on either a CBC basis or an aggregated basis.

Specified jurisdictions list

The Minister's determination of jurisdictions for Public CBC reporting is provided by legislative instrument. The specified jurisdictions are outlined in the Legislative Instrument LI 2024/27 Taxation Administration (Country by Country Reporting Jurisdictions) Determination 2024.

Specified jurisdictions

Specified jurisdictions that have a comprehensive international tax agreement with Australia:

Singapore
Switzerland.

Other specified jurisdictions

The following is a list of other specified jurisdictions:

Andorra
Anguilla
Antigua and Barbuda
Aruba
Barbados
Bahamas
Bahrain
Belize
Bermuda
British Virgin Islands
Cayman Islands
Cook Islands
Curacao
Dominica
Gibraltar
Grenada
Guernsey
Hong Kong
Isle of Man
Jersey
Liberia
Mauritius
Monaco
Montserrat
Nauru
Niue
Panama
Republic of the Marshall Islands
Saint Kitts and Nevis
Saint Lucia
Saint Maarten (Dutch Part)
Saint Vincent & the Grenadines
Samoa
San Marino
Seychelles
Turks and Caicos Islands
US Virgin Islands
Vanuatu.

Public CBC information to be reported

The Public CBC reporting parent is required to publish the following information:

its own legal name and the name of its tax jurisdiction
the reporting period year, end date and start date
the names of each entity in the CBC reporting group
a description of the CBC reporting group’s approach to tax
information about Australia and specified jurisdictions, on a CBC basis
information about its other jurisdictions, either on a CBC or aggregated basis.

Information required to be reported

If the Public CBC reporting parent chooses to report on a CBC basis for all jurisdictions in which the group operates, it doesn't need to publish any information on an aggregated basis.

However, if the Public CBC reporting parent only publishes information on a CBC basis for Australia and the specified jurisdictions, it must publish information for all other jurisdictions on an aggregated basis.

Australia and specified jurisdictions

The Public CBC reporting parent is required to publish the following information for Australia and specified jurisdictions:

name of the jurisdiction
description of main business activities
number of employees (on a full-time equivalent basis) at the end of the reporting period
revenue from unrelated parties
revenue from related parties that are not tax residents of the jurisdiction
profit before income tax
loss before income tax
book value at the end of the reporting period of tangible assets, other than cash and cash equivalents
income tax paid (cash basis)
income tax accrued (current year)
reason for the difference between income tax accrued and profit or loss before income tax multiplied by the income tax rate
currency used in calculating the tax information.

Other jurisdictions (aggregated information)

The Public CBC reporting parent is required to publish the following information on an aggregated basis for all other jurisdictions in which the group operates:

consolidated summary of the main business activities in all other jurisdictions
number of employees (on a full-time equivalent basis) at the end of the reporting period
revenue from unrelated parties
revenue from related parties that are not tax residents of the jurisdiction
profit before income tax
loss before income tax
book value at the end of the reporting period of tangible assets, other than cash and cash equivalents
income tax paid (cash basis)
income tax accrued (current year)
currency used in calculating and presenting this information.

Guidance

The information you must report has been adopted from the Global Reporting Initiative (GRI) 207: Tax 2019External Link (GRI 207) reporting standard. Some terminology differs to ensure consistency with how these concepts are understood in Australia, both under Australian domestic law and Australian accounting standards.

The Base Erosion and Profit Shifting (BEPS) Action 13 Guidance and the Organisation for Economic Co-operation and Development (OECD) transfer pricing guidelines provide further contextual guidance having regard to Public CBC.

The words of the law should be applied first after which regard may be had to aforementioned additional guidance. To the extent of any inconsistency or differences in terminology, treat GRI Disclosures 207-1 and 207-4 of GRI 207: Tax 2019 as prevailing over The BEPS Action 13 Guidance and the OECD transfer pricing guidelines.

For more information, see:

Publishing the information

The Public CBC reporting parent is required to publish the information on an Australian Government website by giving the information in the approved form to us. The approved form is an XML file that conforms to the Public CBC XML Schema, and lodgment is via email. Upon lodgment, we will send an email acknowledging receipt. Once we've validated and processed your lodgment, we will either:

confirm that we are preparing your report to upload to data.gov.auExternal Link, or
advise that your report cannot be uploaded to data.gov.auExternal Link, including details of any errors or omissions. You'll need to correct the issues and re-publish the corrected report before we can upload to data.gov.auExternal Link.

For instructions on completing the approved form, see Instructions to complete the Public country-by-country report.

Digital service providers

Digital service providers can access the:

Our role

We will facilitate the publication of the reported information as soon as practicable on data.gov.auExternal Link.

The first publication is expected to be released in late 2026.

Extension of time to provide the Public CBC report

The Public CBC report is due within 12 months after the end of the relevant reporting period. For example, for the reporting period ending 30 June 2025, the Public CBC report is due by 30 June 2026.

A Public CBC reporting parent may apply to us for an extension of time to provide the Public CBC report. The Public CBC reporting parent can submit their request for deferral via email at PublicCBC@ato.gov.au.

Correcting errors

If a Public CBC reporting parent becomes aware of a material error in any of the published information, they must rectify the error by providing the corrected information to us.

To amend your Public CBC report, complete the approved form again with the corrected information and publish it using the same Public CBC reporting submission process. The amended report will replace the original report published. All fields must be completed in the amended 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, we will consider an entity aware of a material error once its accountant or tax manager realises the error and prepares an amendment to the entity's income tax return, necessitating an amendment to its Public CBC report.

Penalties apply for non-compliance.

What is a material error

Whether an error is material is a matter of professional judgment. The relevant accounting standard must be used to determine whether an error in an item, or an aggregate of items is material and must be corrected. An error is material if not correcting it means information is omitted, misstated, or obscured where this could be reasonably expected to influence the fair presentation of your Public CBC report.

Non-material errors

The entity may choose to rectify the non-material error by publishing the Public CBC report in the approved form again with the corrected information and using the same Public CBC reporting submission process. The amended report will replace the original report published. All fields must be completed in the amended Public CBC report, including fields that have not been changed.

Uploading to data.gov.au

If a material or non-material error is rectified by the Public CBC reporting parent, we will upload the corrected information on the data.gov.auExternal Link as soon as practicable. 

Exemptions to Public CBC reporting

The purpose of Public CBC reporting is to enhance tax transparency. However, a Public CBC reporting parent may seek an exemption from its reporting obligations. The Commissioner of Taxation has the discretion, for a single reporting period, to grant a Public CBC reporting parent entity either a:

full exemption
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 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 the information we expect entities to provide with their 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 lodgement due date. An exemption only applies to the reporting period for which it is granted.

How to apply for a Public CBC reporting exemption

To apply for a full or partial exemption, or to notify us of your exemption status (Government Related Entities), download the Public country-by-country reporting exemption and exclusion application form (DOCX, 140KB)This link will download a file.

To submit your application, email the completed form along with all attachments to PublicCBCExemption@ato.gov.au.

For Australian entities with a 30 June 2026 Public CBC reporting deadline who are considering an exemption request, we encourage the submission of an exemption application as soon as possible. For those with a 31 December 2026 reporting deadline, early engagement will support a smoother exemption assessment process.

Where an entity has engaged with us in a timely and reasonable way, and in a manner consistent with Law Administration Practice Statement PS LA 2025/2, we will work with the applicant to progress the exemption decision, and, where necessary, use administrative mechanisms to manage lodgment timing.

Submitting your exemption request

To submit your Public CBC reporting exemption request, you must:

specify the information and jurisdiction for which an exemption is sought
explain the reasons that apply
provide relevant supporting information and documentation, and
confirm authorisation to submit the request and engage with us on behalf of the applicant.

Where your request doesn't provide sufficient information or documentation, we will request this and discuss any concerns with you.

To help us to consider your application, we suggest you include the following:

if requesting a full exemption, the reasons why a partial exemption would not be sufficient
explain what is unusual or exceptional about your circumstances to justify an exemption
detail any link between the specific disclosure or disclosures for which an exemption is requested and any harm or adverse consequences that might be caused by public disclosure
explain why the delay in publication of information under Public CBC reporting doesn't sufficiently reduce the potential harm or consequences that might be caused by public disclosure
explain if aggregation of the information is available, why that aggregation doesn't sufficiently reduce the harm or consequence of disclosure, and
why the information for which the exemption is requested is not and isn't expected to become publicly available in full or part through other reporting obligations or channels.

You can find more detailed guidance in Practice Statement Law Administration PS LA 2025/2.

We will engage with you before reaching a decision regarding your exemption application.

You will only be exempt from publishing a partial or full Public CBC report once we have assessed your application and notified you in writing of the exemption that has been granted for that reporting period.

National security matters

A relevant factor for a favourable consideration of an exemption request is where disclosure of specific information in a Public CBC report may impact national security. We acknowledge that considerations relating to national security matters may encompass areas of specialised knowledge or expertise including security, defence, international relations and law enforcement interests of both Australia and other nations.

To ensure that appropriate privacy arrangements are in place, we encourage you to email PublicCBCExemption@ato.gov.au before lodging an application relating to national security matters.

More broadly, we are considering circumstances where information disclosed in a Public CBC report may be likely to generally impact Australia’s national security. This is for the purpose of determining whether disclosing such information publicly would be inappropriate for a class of entities that engage in similar or alike activities.

Government-related entities

Government-related entities may be relieved from Public CBC reporting by written notice from the Commissioner, including:

department of the State of the Commonwealth
Department of the Australian Parliament established under the Parliamentary Service Act 1999
executive agency or statutory agency, within the meaning of the Public Service Act 1999
department of state of a state or territory
local government body established by or under a state or territory law
organisation that satisfies both of the following
- is either established by the Commonwealth, a state or territory (whether under a law or not) to carry on an enterprise or established for a public purpose by an Australian law, and
- can be separately identified by reference to the nature of the activities carried on through the organisation or the location of the organisation.

A government-related entity that is a Public CBC reporting entity can be relieved from reporting for one or more reporting periods by written notice from the Commissioner.

If you’re considering applying for relief from reporting on the basis you are a government-related entity, contact us at PublicCBCExemption@ato.gov.au before lodging.

We will continue to provide further guidance for government-related entities.

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