Country-by-Country (CbC) reporting

This page provides links and information on Country-by-Country (CbC) reporting and transfer pricing documentation.


CbC reporting is part of a broader suite of international measures aimed at combating tax avoidance through more comprehensive exchanges of information between countries. CbC reporting implements Action 13 of the Organisation for Economic Cooperation and Development’s (OECD)/G20 Base Erosion and Profit Shifting (BEPS) Action Plan.

For income years commencing on, or after, 1 January 2016, significant global entities (SGEs) will need to provide us with three statements within 12 months after the end of their income tax year, the:

  • CbC report
  • Master file
  • Local file

SGEs are broadly defined as:

  • global parent entities with an annual global income of A$1 billion or more
  • a member of a group of entities that are consolidated for accounting purposes as a single group, where the global parent entity has annual global income of A$1 billion or more.

For further information on SGEs, refer to Significant global entities on

For further information on CbC reporting, refer to Country-by-Country reporting on


6 April 2017

Local file and Master file

Validation rules are now available and the following technical documents were updated on 6 April 2017. 

  • Message Structure Table (MST)
  • XML schema
  • Sample XML schema compliant file

This documentation is available via the Significant Global Entity Obligations (SGEO) page on

The design of the XML schema is based on the Local File – High Level Design, which outlines our approach to the information requirements in Annex II of the OECD guidance. For the Master file, we have adopted Annex I of the OECD guidance. The Master file will need to be lodged as an attachment to the combined schema.

The XML schema for the local file and master file contains elements relating to the lodgment of the CbC report, however, the CbC report must be separately lodged based on the OECD defined schema, see ‘CbC report’ below.

The statements must be lodged via one of the following ATO approved channels:

For more information on electronic lodgement, please visit our Online services page.

You can email any feedback or questions on the XML schema to the CbC reporting mailbox.

CbC report

The OECD has released the final XML schema (v1.0) for the standardised exchange of CbC reports between jurisdictions. We are adopting the OECD XML schema for the purpose of domestic lodgement of the CbC report.

Key Dates

22 March 2016: OECD releases standardised electronic format for the exchange of BEPS Country by Country Reports

6 October 2015: OECD report supports Australian Government action on multinational tax avoidance

16 September 2015: Introduction of combating multinational tax avoidance bill

Links and documents

Law Companion Guideline LCG 2015/3 Subdivision 815-E of the Income Tax Assessment Act 1997: Country by Country reporting

OECD Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 - 2015 Final Report

OECD CbC Report XML Schema and User Guide

Contact information

Feedback can be sent to