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Australian public country-by-country reporting – are you prepared?

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  • 10 minute read
  • 06 Mar 2026

Australia’s new public country‑by‑country reporting regime introduces far‑reaching tax transparency obligations for large multinationals. Affected groups will need to closely consider and carefully plan for upcoming disclosures.

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In brief

The first reporting deadline under Australia’s new public country-by-country reporting (CBCR) regime is fast approaching, and the compliance burden for large multinationals is significant. In-scope groups will soon be required to publicly disclose detailed tax and financial information on a jurisdiction-by-jurisdiction basis, under a regime that differs in important ways from both the OECD’s confidential CBCR framework and Europe’s public CBCR requirements. With the first reports due to be lodged with the Australian Taxation Office (ATO) as early as 30 June 2026, and penalties of up to AUD $825,000 for non-compliance, time is short. 

This alert sets out the key features of the new rules, highlights the important differences from other reporting regimes, and outlines the practical steps your organisation should be taking now to prepare.

In detail

Recap on Australian public CBCR requirements

Who must report
  • An entity must report under Australia’s public CBC regime for a period if all of the following apply:
    • It is a constitutional corporation, or a trust/partnership where all trustees/partners are constitutional corporations.
    • It is a CBC reporting parent for part or all of the preceding period. Importantly, this refers to the Australian legislative definition of CBC reporting parent, which is the ultimate parent entity of a group with consolidated annual global income of AUD$1bn or more. In some cases, foreign parent entities may meet this threshold even if they fall below the CBCR threshold in their home jurisdiction.
    • It is a member of a CBC reporting group at any point during the period. Again, this refers to the Australian definition, meaning that it is a member of a group with consolidated annual global income of at least AUD$1bn. 
    • At any point during the reporting period, it or another group member was an Australian resident or a foreign resident operating an Australian permanent establishment.
    • The group’s Australian-sourced aggregated turnover for the reporting period is AUD$10m or more. 
What must be reported 
  • Group information:
    • Legal name of the CBC reporting parent
    • Names of all entities in the CBC reporting group
    • Description of the group’s approach to tax in line with Global Reporting Initiative’s Sustainability Reporting Standards GRI 207-1. This will likely need to be signed off by the Board or a similar senior executive body and requires the following contents:
      • A description of whether the organisation has a tax strategy (and a link to that strategy if publicly available)
      • The governance body within the organisation that is responsible for approving the tax strategy, and how frequently the strategy is reviewed
      • The approach to regulatory compliance
      • How the approach to tax is linked to wider business and sustainable development strategies of the organisation.
  • Jurisdictional information: 
    For Australia and each of the specified jurisdictions (including Singapore, Switzerland, Hong Kong, and others), the following must be reported on a CBC basis:
    • Name of the jurisdiction
    • Description of main business activities
    • Number of employees (full-time equivalent) at period end
    • Revenue from unrelated parties
    • Revenue from related parties not resident in the jurisdiction
    • Profit or loss before income tax
    • Book value of tangible assets (excluding cash and equivalents) at period end
    • Income tax paid (cash basis)
    • Income tax accrued (current year)
    • Reasons for any difference between income tax accrued and the amount due if the statutory tax rate were applied to pre-tax profit
    • Currency used in calculating and presenting the above information.

For all other jurisdictions, the above information can be reported on an aggregated ‘Rest of World’ basis, unless the parent chooses to report on a CBC basis for all jurisdictions. If the group has any stateless entities, these will always be reported in the ‘Rest of World’ data, even if the group volunteers to report all other jurisdictions on a CBC basis. 
How is this to be prepared and lodged
  • Data source for information included in the report: 
    • Financial information should be based on consolidated audited financial statements, or if not prepared, information which would have been reported in the consolidated financial statements. You are required to be able to reconcile the information reported to the consolidated financial statements.
  • Registration
    • As the reporting obligation sits with the parent entity of the group, many non-resident parents will need to engage with the Australian tax system for the first time. There is a process available for public CBC reporting parent entities to register with the ATO. 
    • The PDF registration form should be filled and signed electronically and emailed to the ATO. It should not be printed or scanned. 
    • Registration allows the parent entity to authorise representatives (including Australian employees, or an Australian tax agent) to act on its behalf for public CBC reporting purposes, including lodging reports and applying for exemptions or extensions. Entities are encouraged to maintain their own internal records evidencing the basis upon which authority has been delegated to the individual/s nominated in the form. 
    • Public CBC reporting parents are encouraged to register at least 4 weeks before the date they intend to first engage with the ATO on a public CBC matter.
  • Preparation and lodgment of report
    • The report must be submitted in the approved form, which is an XML schema designed by the ATO. 
    • The ATO has published instructions on preparing the public CBCR. Notable points in the instructions include:
    • Entities with approved exemptions will be expected to submit a file indicating that they have been granted an exemption. For entities with partial exemptions, they will indicate the applicable exemption/s in the file and disclose the remaining information. 
    • No guidance has been provided on what will be considered a ‘material discrepancy’ requiring explanation in relation to the income tax expense accrued for a jurisdiction relative to the headline corporate tax rate applied to profit before tax. 
    • The instructions and schema do not specifically mention any requirement to include a link to the entity’s European public CBCR. This is mentioned in the Explanatory Memorandum to the Bill that introduced the law but it does not seem to be a required element of the final ‘approved form’. 
    • The XML file must be submitted to the ATO by email, after it has been verified as ‘true and correct’ by an authorised representative of the reporting entity.
    • According to the ATO’s instructions, an entity will only be considered to have complied with its obligations after the ATO has received the approved XML file and uploaded it to data.gov.au (the Government website where the reports will be published). If the ATO identifies errors in the file that prevent it from uploading the data to the website, the ATO will contact the entity to inform them of the errors or omissions identified, and will ask the entity to resubmit a corrected report. 
    • Entities are also required to resubmit an amended report if they identify a ‘material error’ in a report they have filed. It will be a matter of professional judgment to assess whether an error is material. This should be considered having regard to the relevant accounting standards.
When is this due

  • Australia’s public CBCR rules apply for accounting periods of the CBCR parent beginning on or after 1 July 2024, with submission due 12 months after year-end. 

  • June year end entities will need to submit their 30 June 2025 public CBCR by 30 June 2026.

  • December year end entities will need to submit their 31 December 2025 Public CBCR by 31 December 2026.

  • This will be an ongoing annual obligation for entities who remain in the scope of the rules

  • It may be possible to apply for an extension of time to lodge the public CBCR under certain circumstances.

  • Material errors must be corrected within 28 days of discovery.
Why is this important

  • Public disclosures of detailed company information will be required, which for most entities will be much more detailed than they have published previously. Based on PwC’s 2025 Tax Transparency study, only 3.5% of large companies studied globally had published CBC data prior to the introduction of mandatory public CBCR regimes. The new Australian public CBCR regime and similar requirements in Europe will lead to significant additional information being available to the public for the first time. 

  • Penalties of up to AUD$825,000 can apply for failing to comply with the publishing deadline or for failing to correct material errors on a timely basis.

Exemptions

Exemptions from the regime are at the discretion of the Commissioner of Taxation. In December 2025, the ATO published the final Practice Statement Law Administration (PSLA) 2025/2 governing how it will administer exemptions from the public CBCR regime.

Exemptions are expected to be granted only where there are ‘exceptional circumstances’ - that is, unusual or significant circumstances that make disclosure inappropriate. A reporting entity may seek an exemption on any grounds; however, the following examples are provided of the kinds of matters that may be appropriate to consider:

  • Impact on national security 
  • Breach of Australian law. 
  • Breach of the law of another jurisdiction.
  • Disclosure of genuinely commercially sensitive information that would result in severe consequences for the entity.

Exemptions may also be considered in other circumstances, such as if the parent is based in a jurisdiction with its own public CBCR regime and the group falls below the reporting threshold for that regime. Unlike the confidential CBCR regime:

  • Exemptions may not always be available in situations where the parent’s income falls below the confidential CBCR threshold in its home jurisdiction (although a request can be made in that case if there are other factors supporting an exemption). This means that some parent entities who are not required to file a confidential CBCR could have a public CBCR obligation in Australia. 
  • Exemptions will not be available to Australian parent entities with no foreign operations. 

Key points relevant to applying for an exemption include:

  • Entities are encouraged to register with the ATO prior to seeking an exemption (as discussed earlier). 
  • An application form should be completed and submitted with supporting evidence. Broadly, the application should include:
    • The information and jurisdictions for which an exemption is sought 
    • A detailed explanation of the grounds for exemption 
    • Relevant supporting documents and evidence (e.g., contracts, financial statements) 
    • Authorisation to submit the request and engage with the ATO on behalf of the applicant (if being submitted by a third party such as a tax agent)
    • The application form is generally submitted by email, but if a more secure mode of submission is required, this can be requested by contacting the ATO.
  • For exemptions related to national security interests, the ATO should be contacted prior to lodging.
  • Applications for exemptions can be made in writing before or after the end of the relevant reporting period, but only one application will be considered per period.  
  • If an exemption is approved for a period, and the relevant circumstances remain the same in a later period, a streamlined process will be available to seek a similar exemption for the next two years. 
  • More detailed guidance can be found in PS LA 2025/2.

Comparisons with other regimes

The information that is required to be reported in the Australian public CBCR differs from both the existing OECD confidential CBCR and the public CBCR requirements in Europe. This means preparing the Australian public CBCR will not be a simple ‘copy and paste’ exercise. The key differences are outlined in the table below. 

Requirement AU public CBCR EU public CBCR (minimum standard) OECD Confidential CBCR
Data source Consolidated financial statements

Any of:

  • Consolidated financial statements

  • Local entity financial statements

  • Regulatory financial statements

  • Management accounts
Related party revenues International related party revenues required Not required to be separately reported Combined domestic and international related party revenues reported
Number of employees Full-time equivalent (FTE) employees at the end of the period FTE employees in the year (no specific point in time specified) FTE employees at end of year, average, or any other reasonable basis (provided it is consistent across jurisdictions and years)
Explanation of effective tax rate (ETR) variances Required for Australia and specified jurisdictions Option to include explanations of differences between tax accrued and tax paid Not required
Which countries must be separately reported Australia and certain ‘specified jurisdictions’, including Singapore, Switzerland, Hong Kong EU member countries plus certain ‘non-cooperative’ jurisdictions All countries
Approach to tax statement Required Not required Not required
Filing & publication mechanism

  • Parent must file with ATO

  • ATO will publish on data.gov.au website

Varies by member state

  • In some cases self-publication is accepted

  • Filing with a local regulator may also be required

  • Parent (or nominated surrogate) files with home tax authority

  • File shared with other tax authorities but not published

We note that the European reporting requirements are subject to variations by each member state. Entities subject to the European rules should check the applicable local requirements. 

What you should be doing now

Reporting entities should be considering the following as immediate next steps:

  • Filing obligations: Determine whether you have a filing requirement under the Australian public CBCR rules.
  • Registration: If you have a filing obligation in Australia, consider the registration process and the nomination of an appropriate authorised representative who will be responsible for approving the report prior to filing.
  • Internal readiness:
    • Consider the availability of required information from internal systems and any actions needed to address gaps in the data.
    • Establish processes to prepare and approve the relevant disclosures including the tax approach statements and the ETR explanations.
    • Engage with relevant internal stakeholders and ensure board-level awareness of public disclosures. 
    • Consider whether to self-publish additional contextual information to explain the public CBCR data. 
    • Implement tracking mechanisms to ensure deadlines are met. 

How PwC can help: 

  • Review whether the Australian public CBCR rules to you
  • Assist with registration process (including nomination of PwC Australia as tax agent, if applicable)
  • Advise on potential exemption eligibility and assistance with application, if applicable
  • Readiness assessment and process review (based on your most recent CBC report and tax policy statements)
  • Assist with preparation of preparation or review of your Approach to Tax statement, and broader tax transparency reporting
  • Assist with preparation or review, conversion and lodgment of the public CBCR
  • Automation of public CBCR preparation, together with preparation of data for your confidential OECD CBCR, European public CBCR, and Pillar Two safe harbour calculations
  • Assistance with analysis of public and private CBCR data. 
  • Assistance with stakeholder communications. 

Key takeaways

  • Assess your scope independently. Don’t assume existing OECD or EU CBCR filing positions determine your Australian public CBCR obligations - the criteria are distinct. 
  • Register with the ATO early. Allow at least four weeks before you need to engage with them. Identify who will be responsible for authorising the public CBCR prior to lodgment and document your internal processes for nominating the authorised representative/s nominated in the registration form. 
  • This is not a copy-and-paste exercise. The Australian regime differs from other CBCR regimes in data requirements, jurisdictional thresholds, and disclosure obligations.
  • Get your data and processes in order. Reports must be reconcilable to consolidated audited financial statements and lodged in the ATO’s prescribed XML format.
  • Prepare for public scrutiny. Engage internal stakeholders, including the board, early, and consider self-publishing additional context alongside the report.
  • Don’t rely on exemptions. These are at the Commissioner’s discretion and expected only in “exceptional circumstances”.
Contact us

Sarah Stevens

Managing Director, Tax, PwC Australia

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Georgie Hockings

Partner, Tax & Legal, PwC Australia

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Nick Houseman

Partner, International Tax Leader, PwC Australia

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Greg Weickhardt

Partner, Global Tax, Melbourne, PwC Australia

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Sarah Saville

Partner, Tax Reporting and Innovation, PwC Australia

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Chris Vanderkley

Special Counsel, PwC Australia

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