Federal Budget 2026-27: expert insights on spending, tax reform and policy impacts. Visit hub.
Public CbC reporting parents are required to comply. The rules apply to MNEs with global income of A$1 billion or more that are not controlled by another group entity. MNEs is required to have an Australian presence, either headquartered. or through subsidiaries or a permanent establishment, and the regime only applies where Australian sourced aggregated turnover is at least A$10 million. What that means for you is a clear threshold test that brings large groups into scope.
The reporting obligation sits with the Public CbC reporting parent, not the Australian subsidiary unless it independently qualifies. Reports must be lodged with the ATO within 12 months of the end of the reporting period. Significant penalties apply for missing deadlines.
Disclosures cover revenue, profit, income tax paid and accrued, employee numbers, tangible assets, business activities and the group’s approach to tax.
Data is required to be reported on a country-by-country basis for Australia and specified jurisdictions such as Hong Kong, Singapore and Switzerland . For other jurisdictions, entities may choose between country-by-country or aggregated reporting. Information must be lodged in XML format and will be published on an Australian Government website. This means public scrutiny and not just regulatory review.
The Commissioner may grant full or partial exemptions for a single reporting period, based on factors such as national security, legal restrictions or commercial sensitivity. Applications must be supported by clear evidence. Penalties apply for non‑compliance, reinforcing the importance of governance, and timely and accurate reporting.
Our support can provide focus for you when preparing for public disclosure including building governance frameworks, strengthening data collection and preparing clear, compliant reports that meet ATO expectations and gives your business confidence. Our team can help your business reduce compliance risk, protect its reputation, and stay ahead as global transparency standards continue to evolve.
The ATO’s draft PCG 2026/D1 introduces a new compliance framework for attributing risk weighted assets to Australian branches of foreign banks, reshaping thin capitalisation methodologies and documentation expectations.
PepsiCo embedded royalties, ATO Decision Impact Statement, embedded royalties Australia, royalty withholding tax, diverted profits tax, intellectual property payments, IP arrangements Australia, multinational tax Australia, ATO royalties guidance
US tariffs and IEEPA changes impacts on Australian exporters and trade compliance.
Subscribe now to be kept up-to-date with timely and relevant insights, unique to the nature of your business, your areas of interest and the industry in which you operate.
Tax Agents Disclosures
The Tax Practitioners Board maintains a register of tax agents and BAS agents. You can access and search this register here. This register includes details of the registration (and conditions if applicable) of Grant Thornton and our individual registered tax agents with whom you engage.
Your engagement letter with Grant Thornton and the Standard Terms and Conditions set out our procedures for dealing with problems or complaints. The Tax Practitioners Board also has a complaints process in relation to tax agent services as outlined on their website which can be accessed here.
Tax agents have obligations to the Tax Practitioners Board and to their clients. You also have obligations under the taxation laws and to your tax agent. Please refer to these obligations on the TPB website or the TPB’s fact sheet "Information for Clients".
Section 45 of the Tax Agent Services (Code of Professional Conduct) requires Grant Thornton to notify you if it becomes aware of certain events which have occurred in the past 5 years. Grant Thornton is not aware of any such events.