Under Australian tax laws, there are special reporting obligations and integrity measures that apply to an entity that is a ‘significant global entity’ (SGE) and/or a ‘country- by-country reporting entity’ (CBCRE). Broadly, an SGE or CBCRE is an entity which has annual global income of AUD1 billion or more, or which is part of a group of entities consolidated for accounting purposes that has annual global income of AUD1 billion or more.
Since 2015, the Australian Government has been progressively introducing tax laws targeted at SGEs and CBCREs and expanding the definitions to capture more entities. These include additional reporting obligations in the form of Country-by-Country (CbC) reporting and a requirement to lodge General Purpose Financial Statements (GPFS) with the Australian Taxation Office (ATO) where not already lodged with the Australian Securities and Investment Commission (ASIC), and targeted integrity measures in the form of the Multinational Anti-Avoidance Law (MAAL) and the Diverted Profits Tax (DPT). In addition, SGEs are subject to significant administrative penalties for failing to meet their tax obligations.
The consequences for an entity that is an SGE or CBCRE are significant. This publication reviews the SGE and CBCRE concepts and summarises the different rules which can apply under Australian tax law. Read the full report below.
Jason Karametos
Partner, Corporate Tax Leader, PwC Australia
Georgie Hockings
Partner, Tax & Legal, PwC Australia
Greg Weickhardt
Partner, Transfer Pricing and Trade Leader, PwC Australia
James O'Reilly
Partner, Brisbane Tax Leader & Global Energy, Utilities and Mining Tax Leader, PwC Australia
Tamika Cullen
Perth Corporate Tax Leader, PwC Australia
James Nickless
Partner, Tax, PwC Australia