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 ato.gov.au.
- CbC reporting, refer to Country-by-Country reporting on ato.gov.au.
5 May 2017
Due to prioritisation in delivery of the tax time schedule, the conformance test suite for the local file will be available for software developers on 15 June. To support reporting software delivery for the first reporting year, we will provide a lodgment concession for December balancers who choose to take up the local file administrative solution.
Local File administrative solution – lodgment concession
Under the administrative solution for the local file, a Reporting Entity may choose to voluntarily lodge Part A of their local file at the same time as their Income Tax Return. If a Reporting Entity chooses this option, they will not need to complete the relevant International Related Party Dealings (IRPD) labels in Questions 2 to 17 of the International Dealings Schedule (IDS).
Part B of the local file must be lodged by the statutory due date (per 815-355(2) of the Income Tax Assessment Act 1997). The administrative solution is only available in relation to lodgments due on or after 1 July 2017 using 2017 stationary.
For December 2016 balancers who choose to take up the administrative solution, the Income Tax Return together with an IDS and Part A of the local file will be due by 15 July 2017.
Under the lodgment concession, Reporting Entities that are December balancers and choose to take up the administrative solution will have until 15 August 2017 to lodge the Income Tax Return, Part A of the local file and the remaining labels of the IDS. This is a lodgment concession only and does not change the due date for payment, if required.
We will not apply a FTL penalty to December balancers that choose to take up the administrative solution when their Income Tax Return together with an IDS and Part A of the local file is lodged by 15 August 2017.
27 April 2017
Local file and Master file
The following technical documents are available via Significant Global Entity Obligations (SGEO) page on sbr.gov.au.
- Message Structure Table (MST)
- XML schema
- Validation rules
- Sample XML schema compliant file
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. A detailed overview of the combined schema's information is available.
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:
- Business Portal / Tax Agent Portal using the File Transfer Facility
- Standard Business Reporting (SBR) using SBR-enabled software.
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.
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.
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
Feedback can be sent to CbCReporting@ato.gov.au