Who must comply with Country-by-Country Report (CbC) for significant global entities?

Australian entities in multinational groups with >EUR 750M consolidated global income.

What is the maximum penalty for Country-by-Country Report (CbC) for significant global entities?

Failure-to-lodge penalty + administrative penalties for false statements

What evidence is required for Country-by-Country Report (CbC) for significant global entities?

CbC Report, Master File, Local File lodged via Online services for business.

Lodge Country-by-Country Report (CbC) for significant global entities (2026)

Summary

Subdivision 815-E of the ITAA 1997 requires Significant Global Entities (consolidated annual global income >EUR 750M) to lodge a Country-by-Country Report, Master File and Local File with the ATO within 12 months of the end of the income year. Filings are automatically exchanged with foreign tax authorities under MCAA on CbC.

Enforced by

ATO

Source legislation

income tax assessment act 1997

Topics

taxcbcinternational

Related obligations

CWLTHMaintain transfer pricing documentation (Subdivision 815-D)Multinational groups must keep contemporaneous transfer pricing documentation per Subdivision 815-D ITAA 1997.
CWLTHAustralian Business Number (ABN) applicationEntities carrying on an enterprise in Australia need an ABN — without one, payers must withhold 47% PAYG from your payments. How to apply and who's eligible.
CWLTHLodge Business Activity Statements at assigned frequencyGST-registered entities must lodge a BAS monthly, quarterly or annually as the ATO assigns.
CWLTHMake trustee resolutions for trust distributions by 30 JuneDiscretionary trust trustees must validly resolve to distribute trust income before the end of the FY.
CWLTHForeign bribery offence (Criminal Code Division 70)Bribing a foreign public official is a federal criminal offence — up to 10 years imprisonment.
CWLTHWithhold PAYG from employee and contractor paymentsEmployers must withhold tax from wages, certain contractor payments + report via STP / BAS.

Frequently asked questions

Who must comply with Country-by-Country Report (CbC) for significant global entities?: Australian entities in multinational groups with >EUR 750M consolidated global income.
What triggers Country-by-Country Report (CbC) for significant global entities?: Being a Significant Global Entity.
When is Country-by-Country Report (CbC) for significant global entities due?: Within 12 months of end of income year.
What is the maximum penalty for Country-by-Country Report (CbC) for significant global entities?: Failure-to-lodge penalty + administrative penalties for false statements
What evidence is required for Country-by-Country Report (CbC) for significant global entities?: CbC Report, Master File, Local File lodged via Online services for business.