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In Australia, CbC reporting obligations apply to Country‑by‑Country Reporting Entities (CBCREs), being multinational groups with annual global revenue of A$ 1 billion or more. These entities are required to file three types of reports with the Australian Taxation Office (ATO): the CbC report, the master file, and the local file. Together, these documents provide a comprehensive view of the group’s global operations, transfer pricing policies, and financial results by jurisdiction.
The CbC report presents aggregated data by jurisdiction, including revenue, profit before tax, income tax paid and accrued, employee numbers, capital, retained earnings and tangible assets. This information helps tax authorities identify transfer pricing risk and potential profit shifting.
The master file provides a high‑level view of the group’s global business and transfer pricing framework. It outlines organisational structure, key activities, intangibles and intercompany financing arrangements. It provides the ATO with clearer context for the CbC data and insight into how value is created across the group. The ATO expects the master file to align with OECD guidance and to be lodged annually.
The Australian local file focuses on the Australian entity and its related party dealings. It consists of the Short Form Local File, Part A and Part B.
The Short Form Local File (SFLF) is mandatory for all CBCREs, even where there are no international related party dealings. For reporting periods starting on or after 1 Jan 2024, the ATO significantly expanded the SFLF, replacing free‑text responses with structured and more detailed disclosures.
The SFLF now requires disclosures across several key areas:
Automatic exemptions no longer apply. All CBCREs must complete the SFLF.
Part A of the Local File focuses on transactional data relating to IRPDs. Entities must report:
This information gives the ATO a clear view of the scale and nature of cross‑border dealings.
Part B contains qualitative support for the transactions reported in Part A, including copies of intercompany agreements.
Together, the local file enables the ATO to assess whether related party transactions reflect arm’s length outcomes and where compliance risk may sit.
We assist our clients in meeting their CbC reporting obligations by preparing compliant documentation, reviewing transfer pricing policies, and advising on risk mitigation strategies. Our team stays abreast of evolving ATO requirements and international developments to ensure clients maintain transparency while protecting commercially sensitive information. Whether you are preparing your first CbC report or responding to new disclosure requirements, we provide tailored support to help you navigate this complex regulatory landscape.
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