In November 2025, the Australian Taxation Office (ATO) decided to extend the deadline for multinational companies to file their transfer pricing reports for the fiscal year ending December 31, 2024. The new deadline for filing the Country-by-Country Report (CBC), the master report, and the local report is January 30, 2026. This extension reflects the complexity and operational burden companies face in complying with international transparency standards.
What is the Country-by-Country Report (CBC) in Australia?
The Country-by-Country Report is part of the international framework known as BEPS Action 13, promoted by the OECD to combat base erosion and profit shifting.
Under Australian law, these obligations are set out in Subdivision 815-E of the Income Tax Assessment Act 1997.
Qualifying companies must prepare and submit three key documents within 12 months of the end of the fiscal year:
- Country-by-Country Report: report with aggregate data for the multinational group by jurisdiction (revenue, profits, taxes, employees, assets).
- Master Report: macro view of global operations, including transfer pricing policy and how functions, assets, and risks (FAR) are organized.
- Local Report: specific details of intra-group transactions in the local Australian entity.
Australia uses two different XML schemas for filing:
- The CBC Report uses the official OECD schema, which is compatible with the international standard for automatic exchange between tax administrations.
- For the Master File and Local File, the Australian Taxation Office (ATO) requires its own XML schema, called LCMSF, which structures the information in a more granular way—for example, separating different parts of the local file—and allows the ATO to perform specific validations aimed at identifying risks in the Australian context.
This dual schema ensures that Australia complies with OECD standards for international CBC exchange, while retaining a specialized format for local transfer pricing risk analysis.
Who is required to report?
The obligation to file the Country-by-Country Report (CBC), the Master Report, and the Local Report does not apply to all companies, but only to those that fall into the category of CBC reporting entity, as defined in Subdivision 815-E.
According to the ATO, a CBC reporting entity can be:
- The parent entity of the group (“CBC reporting parent”)
This is the main entity or Ultimate Parent Entity (UPE) whose multinational group has consolidated global revenues equal to or greater than AUD 1 billion.
If this entity is located in Australia, the group is automatically required to report.
- An entity that is part of the multinational group in Australia
Even if the Australian entity is not the parent, it must report when it is part of a group whose UPE exceeds the AUD 1 billion threshold and is not controlled by another entity within the same group for accounting purposes.
In simple terms:
If the multinational group exceeds the global threshold, any Australian entity in the group may be required to report, even if it is not the parent.
- Surrogate Parent Entity
If the group parent (PUE) is located in a country that does not exchange CBC Reports with Australia, the group may voluntarily designate another entity—located in a jurisdiction that does participate in the exchange—to file the CBC Report on behalf of the entire group.
This ensures that the ATO receives the international report, even if the parent company is in a non-cooperative jurisdiction.
Exemptions and Administrative Relief
As of January 1, 2025, the ATO has updated its exemption policy for companies that would normally file these reports.
Some scenarios where an exemption or relief may be requested:
- The group has no operations outside Australia.
- The foreign “CBC reporting parent” has high global revenues (≥ A$1 billion), but its country of residence does not exceed certain thresholds for CBC reporting.
- The reporting entity is no longer part of the group (e.g., following a divestiture) and will not rejoin the group in the short term.
In some cases, part of the reporting can be avoided if another entity in the group (surrogate parent) already reports for automatic exchange with Australia.
Public CBC Reporting
In addition to the exchange between tax authorities, the ATO has introduced a Public CBC Reporting regime for certain companies:
- Public reporting applies to Ultimate Parent Entities (UPEs – the ultimate parent entity of the group, i.e., the entity that consolidates financial statements and is not controlled by any other entity – from the fiscal period beginning on July 1, 2024.
- These entities must submit the public report within 12 months of closing their fiscal period.
- The public report includes data by jurisdiction such as: number of employees, revenue from related and unrelated parties, pre-tax profit, tax base, taxes paid, tangible assets, etc.
- The report is submitted in an approved XML format (not necessarily with all the details available in the exchange between authorities) and published on an Australian government website.
Why is the ATO Extending the Deadline?
The extension to January 30, 2026, responds to the operational complexities of complying with the three reports (CBC, Master Report, and Local Report). Many companies face challenges in gathering global data, structuring the information according to the required XML schema, and coordinating with other jurisdictions to exchange information.
The extension provides more time to prepare quality reports, but it also underscores the ATO’s willingness to ensure compliance with BEPS transparency standards without imposing an excessive operational burden that could result in errors or non-compliance.
Risks and Challenges for Companies
- High administrative burden: Consolidating global financial data, defining functions and risks, and preparing reports in XML format is complex and costly.
- Public exposure: For entities subject to public CBC reporting, some global tax information will be visible to third parties, which may have reputational implications.
- International coordination: If the primary reporting entity (UPE or “surrogate parent”) does not have an active exchange mechanism with Australia, the obligation may require a special structure to file from another jurisdiction.
- Risk of penalties: Failure to meet deadlines or comply with the required formats may result in penalties under ATO rules.
Conclusion
The ATO’s extension of the deadline reflects both the technical complexity of CBC compliance and the Australian tax authority’s commitment to integrating international tax transparency standards. For multinational groups with operations in Australia, this means strengthening their global transfer pricing strategy, investing in data consolidation systems, and preparing clear communication about their public reporting (if applicable).
Adopting best practices (such as notification or the use of a “surrogate parent”) and analyzing available exemptions can help manage risk and compliance burden efficiently.
Do you need support with your CBC obligations?
The TPC Group team has transfer pricing and international compliance specialists who can help you prepare your reports, review risks, and ensure that your company complies with the standards required by tax authorities.
Contact us for personalized advice.
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