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, please refer to Country-by-Country reporting on ato.gov.au.
22 March 2017
Local file and Master file
The following technical documents are now available in final draft form via the Significant Global Entity Obligations (SGEO) page on sbr.gov.au.
- Message Structure Table (MST)
- XML schema
- 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 Local file.
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.
Further documentation on electronic lodgment and the XML schema, including validation rules, is currently being developed and will be published on the SGEO page on sbr.gov.au. We will inform you when the documentation becomes available.
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