Who must lodge Country-by-Country Report (CbC) for significant global entities?
The applicability test for Lodge Country-by-Country Report (CbC) for significant global entities (ATO), computed across 35 industries, 9 business structures and 6 size bands.
Short answer: Only if
Applies when the business has group revenue ≥ $1B.
What the obligation is
Multinationals with global income >EUR 750M must lodge CbC Report annually.
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.
The applicability test
Applies when the business has group revenue ≥ $1B.
How the regulator frames it: Australian entities in multinational groups with >EUR 750M consolidated global income.
What triggers it: Being a Significant Global Entity.
Jurisdiction: Commonwealth law, so the test is the same in every state and territory.
Which industries are in or out
Outcome across the 35 industries Rules Mate maps (35 of 35: no).
The answer is the same in every industry: no. Industry does not change who must comply.
Business structure and size
Structure does not change the answer across all industries: for every structure the answer is "no".
Size does not change the answer across all industries: at every size band the answer is "no".
Worked examples
Each line is one run of the Rules Mate applicability engine for a single business profile, with the reason the engine gives:
- Pty Ltd company in real estate agents with 6–19 employees, turnover $1M–$3M: does not apply. Requires group revenue ≥ $1B.
What you must do, and when
- When due
- Within 12 months of end of income year.
- Frequency
- Annual
- Evidence to keep
- CbC Report, Master File, Local File lodged via Online services for business.
- Status
- Current
- Priority
- High
Penalty for not complying
Maximum penalty: Failure-to-lodge penalty + administrative penalties for false statements.
Audit or assurance level
Rules Mate has not yet classified the audit or assurance level for this obligation. Any audit, review or certification requirement is set by the regulator source listed below.
Where it sits in the corpus
Rules Mate tracks 37 published obligations tagged "tax", 6 of them rated critical. For a professional services Pty Ltd company with 6–19 employees operating in every state, 7 of those apply outright. This obligation is rated high priority, and is a annual obligation.
Regulator, legislation and tools
Regulated by Australian Taxation Office.
ATO: Federal tax administrator covering income tax, GST, PAYG, FBT, superannuation guarantee, STP, and self-managed super funds. Also administers the Director ID regime via ABRS.
ITAA 1997: Modern federal income tax statute (replaces ITAA 1936 progressively).
Free tools that help with this obligation:
Questions
- Who must lodge Country-by-Country Report (CbC) for significant global entities?
- Applies when the business has group revenue ≥ $1B.
- Do sole traders need to lodge Country-by-Country Report (CbC) for significant global entities?
- No. Across every industry and every size band, the engine's answer for a sole trader is: no.
- Do businesses with 1–5 employees need to lodge Country-by-Country Report (CbC) for significant global entities?
- No (1–5 employees, turnover $100K–$1M).
- When is "Lodge Country-by-Country Report (CbC) for significant global entities" due?
- Within 12 months of end of income year.
Related
Sources
Computed by the Rules Mate applicability engine from the published obligation corpus; facts last checked 3 October 2026. Rules Mate is not a law firm and this is general information, not legal advice. Confirm your position with the regulator source or a qualified adviser before acting.