Australia releases its first public country-by-country reports

The first release is an initial tranche

The release mainly covers groups with 30 June year ends. The government says reports for later periods, including many foreign-owned groups with 31 December year ends, will follow in subsequent tranches. The 382 reports therefore are not a complete population for the first reporting cycle, and the publication should not be used to infer that an absent group is out of scope or non-compliant.^[1]

The reporting framework is already in force

Schedule 4 to the Treasury Laws Amendment (Responsible Buy Now Pay Later and Other Measures) Act 2024 inserted sections 3D to 3DB into the Taxation Administration Act 1953. The regime applies for reporting periods beginning on or after 1 July 2024. It generally reaches a country-by-country reporting parent with at least A$1 billion of annual global income where the group has an Australian resident member or permanent establishment and at least A$10 million of Australian-source income on the statutory aggregated-turnover basis, subject to exclusions and Commissioner exemptions.^[2][3]

Reports contain jurisdiction-level tax information

A report is generally due within 12 months after the end of the reporting period. It identifies the group and relevant entities and includes information on tax approach, employees, revenue, profit or loss before tax, tangible assets and income tax paid and accrued. Australia and jurisdictions specified by legislative instrument are reported separately; other jurisdictions may be aggregated unless the reporting parent elects to provide them individually. The Commissioner must publish the information as soon as practicable after receiving it.^[3][4]

Groups should reconcile public and filed data

The first release gives tax authorities, investors and other users a broader jurisdictional view than Australia’s existing corporate tax transparency publication. A mismatch between the public report and accounts, tax returns or other country-by-country data can prompt questions, but does not by itself establish avoidance or an error. In-scope groups should retain the filed dataset, confirm published information against the submission and use the statutory correction process where they become aware of a material error.^[1][3]