Public Country-by-Country Reporting in Australia 2026: An Accountant's Guide for Multinationals

Australia's mandatory public Country-by-Country (CbC) reporting regime is now in full effect, with the first reports for entities with a 30 June 2025 year-end due by 30 June 2026. For large multinational enterprises operating in Australia, this represents one of the most significant new tax transparency obligations in years — and the penalties for non-compliance are severe. A qualified accountant with multinational tax expertise is essential for navigating these requirements.

Understanding Public Country-by-Country Reporting in Australia

Public CbC reporting requires large multinational groups to publicly disclose detailed tax and financial information to the Australian Taxation Office (ATO), which then publishes the data on the government's data portal at data.gov.au. This is distinct from the confidential OECD CbC reporting that has existed since 2016 — the new regime makes the information publicly accessible.

The regime applies to accounting periods beginning on or after 1 July 2024. For entities with a standard 30 June year-end, the first report covers the year ended 30 June 2025 and must be lodged by 30 June 2026. For entities with a 31 December year-end, the first report covers the year ended 31 December 2025 and is due by 31 December 2026.

The public disclosure of this information represents a fundamental shift in Australia's approach to multinational tax transparency. Investors, journalists, civil society organisations, and the general public will be able to scrutinise the tax affairs of large multinationals operating in Australia in a way that was previously impossible.

Who Is In Scope?

The public CbC reporting requirements apply to multinational groups that meet all of the following criteria:

• Global consolidated annual income of AUD $1 billion or more — this is the primary threshold that determines whether a group is a Significant Global Entity (SGE)
• Australian-sourced aggregated turnover of at least AUD $10 million — the group must have a meaningful Australian presence
• Operations in Australia — either through an Australian resident entity or a foreign resident operating an Australian permanent establishment
• Appropriate entity structure — the ultimate parent entity must be a company, a partnership with only corporate partners, or a trust with a corporate trustee

Groups that meet these criteria are required to lodge a public CbC report regardless of whether they have already lodged a confidential OECD CbC report. The two regimes operate in parallel and have different content requirements.

What Must Be Disclosed?

The public CbC report requires disclosure of both quantitative jurisdictional data and qualitative statements about the group's approach to tax.

The jurisdictional data must cover Australia and a list of "specified jurisdictions" — including Singapore, Switzerland, Hong Kong, and other jurisdictions identified by the ATO as presenting tax transparency risks. For all other jurisdictions, data may be reported on an aggregated "Rest of World" basis.

For each covered jurisdiction, the report must include:

• Revenue: Broken down between revenue from related parties and revenue from unrelated parties
• Profit or loss before income tax
• Income tax paid and income tax accrued
• Stated capital and accumulated earnings
• Number of employees
• Tangible assets other than cash and cash equivalents

The qualitative disclosures must include a statement regarding the group's approach to tax, aligned with GRI 207-1 standards, and explanations for any material differences between income tax accrued and the amount that would be due based on statutory tax rates in each jurisdiction.

Penalties for Non-Compliance

The penalties for failing to comply with public CbC reporting obligations are substantial. Failure to lodge on time, or failure to correct material errors within 28 days of discovery, can result in penalties of 2,500 Commonwealth Penalty Units — currently valued at AUD $825,000.

These penalties apply per reporting period, meaning a group that fails to lodge for multiple years faces cumulative exposure. The ATO has signalled that it will take a firm approach to enforcement, particularly for large multinationals that have the resources to comply.

Additional penalties may apply for providing false or misleading information in a public CbC report. Given that the reports are publicly accessible, any material inaccuracies are likely to attract scrutiny from both the ATO and external stakeholders.

Exemptions and the ATO's Approach

Exemptions from public CbC reporting are not automatic and are granted at the discretion of the Commissioner of Taxation only in "exceptional circumstances." The ATO has published Practice Statement Law Administration (PSLA) 2025/2 to guide the administration of these exemptions.

Grounds for exemption may include national security interests, potential breaches of foreign law, or the disclosure of genuinely commercially sensitive information that would cause severe harm to the entity. Applications must be submitted formally with supporting evidence — a general claim of commercial sensitivity is unlikely to succeed.

The ATO has made clear that exemptions will be granted sparingly. Entities that believe they may qualify should engage their accountant well in advance of the lodgment deadline to prepare a compelling application.

Australian Regulatory Context

Public CbC reporting in Australia is governed by the Tax Laws Amendment (Tax Transparency) Act 2024, which inserted the relevant provisions into the Taxation Administration Act 1953. The regime is administered by the ATO, which has published detailed guidance on its website including the required XML schema for lodgment.

Reports must be submitted in an ATO-approved XML format via the ATO's online services or Standard Business Reporting (SBR) software. The ATO then publishes the data on data.gov.au, making it accessible to the public.

The regime is part of Australia's broader multinational tax integrity package, which also includes the Pillar Two global minimum tax (GloBE rules), the revised thin capitalisation framework, and the Debt Deduction Creation Rules. Large multinationals operating in Australia must navigate all of these measures simultaneously — a task that requires specialist accountants with deep multinational tax expertise.

The ATO's Large Business and International (LB&I) division is responsible for administering the public CbC regime and has dedicated resources to reviewing lodged reports and following up on non-compliance.

Practical Checklist for Affected Entities

Multinational groups that may be in scope for public CbC reporting should work through the following checklist with their accountant:

• Confirm SGE status: Verify whether the group's global consolidated annual income exceeds AUD $1 billion and whether Australian-sourced turnover exceeds AUD $10 million
• Identify the reporting entity: Determine which Australian entity is responsible for lodging the public CbC report on behalf of the group
• Gather jurisdictional data: Collect the required financial and headcount data for Australia and all specified jurisdictions
• Prepare the tax approach statement: Draft the qualitative disclosure regarding the group's approach to tax, aligned with GRI 207-1
• Assess exemption eligibility: If any information may qualify for an exemption, prepare and lodge an application well before the deadline
• Prepare the XML file: Ensure the report is formatted in the ATO's required XML schema and tested before lodgment
• Lodge on time: Submit the report within 12 months of the end of the relevant reporting period to avoid the $825,000 penalty

How MyMoney® Can Help

Public Country-by-Country reporting is a complex, high-stakes obligation that requires specialist multinational tax expertise. The combination of data gathering, qualitative disclosures, XML formatting, and potential exemption applications means that most affected entities will need dedicated professional support.

MyMoney® connects Australian businesses with qualified accountants who specialise in multinational tax compliance, transfer pricing, and ATO reporting obligations. Whether you need help determining whether your group is in scope, preparing your first public CbC report, or managing an exemption application, the right accountant can make the difference between compliance and a six-figure penalty.

Post a Brief on MyMoney® to receive tailored proposals from accountants with multinational tax expertise. Or Browse Accountants to find a specialist who understands Australia's public CbC reporting requirements.