Country-by-Country (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
An entity is an SGE for an income year if it is:
- a global parent entity with annual global income of A$1 billion or more, or
- a member of a group of entities consolidated (for accounting purposes) where the global parent entity has an annual global income of A$1 billion or more.
This definition includes both:
- Australian-headquartered entities (with or without foreign operations)
- the local operations of foreign headquartered multinationals.
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
2 April 2020
From 1 October 2020, we will only accept version 2.0 of the CBC Report schema. Your software will need to support version 2.0 as all prior versions will no longer be supported.
28 March 2019
The CbC reporting package on the Significant global entity obligations (SGEO) page on sbr.gov.au has been updated to reflect changes to the validation rules for the:
- Local File/Master File (LCMSF) 2018 service
- Country-by-Country report (CBC) 2017 service.
These changes are expected to be deployed to EVTE on 18 April 2019 and production in late June 2019.
Only the 2018 LCMSF service can be used to report periods starting on or after 1 January 2017. For lodgments relating to earlier periods, you may use either the 2017 or 2018 LCMSF service.
13 December 2018
A minor update has been made to the CbC report's validation rules to prohibit certain characters from being submitted as part of a lodgment. The updated validation rules are located on the sbr.gov.au Significant global entity obligations page.
This change is expected to go into production on Friday 21 December.
1 August 2018
A fix for issue 817159 (Cardinality issue in the schema) and 858880 (LCMSF107 and LCMSF230) is expected to deploy to the External Vendor Testing Environment (EVTE) on Thursday 16 August.
The fixes are expected to move to production on Saturday 29 September.
As part of this deployment, an updated LCMSF schema will be published on the Significant global entity obligations page.
Additionally, Validation Rule 46 will be relaxed to allow for the CBC Report Notification to be lodged without a Local File or Master File.
18 July 2018
The 2018 CbC Reporting Package has been finalised. The package is located on the sbr.gov.au Significant global entity obligations page.
9 July 2018
We have identified some CbC Report XML files have not met validation rules as stated in the OECD CbC Report XML Schema User Guide (PDF, 1.14 MB) and CbC Status Message XML Schema User Guide (PDF, 1.35 MB). These validation rules are outlined in Table 1:
Table 1 – DocRefID Validation Rules
|Error no.||Validation name||Validation description|
|80000||DocRefID already used||The DocRefID is already used for another record.|
|80001||DocRefID format||The structure of the DocRefID is not in the correct format.
The DocRefID format must be in the following format:SendingCountryCodeFiscalYear-ReportingEntityIN-UniqueRef
DocRefIDs must be unique in space and time.
We are contacting affected parties to facilitate re-lodgment.
All CbC Report XML files must conform to the validation rules outlined in Table 1 and Table 2. Conforming to these requirements will ensure domestically lodged CbC reports meet OECD requirements for exchange via the Common Transmission System.
These validation rules will be not be enforced until later this year (around November 2018), with exact dates to be advised. If you follow the validation rules now, you will avoid the need to amend and re-lodge files at a later stage.
Table 2 - Other Validation Rules
|Error no.||Validation name||Validation description|
|50010||File Contains Test Data for Production Environment||The referenced file contains one or more records with a DocTypeIndic value in the range OECD10-OECD13, indicating test data.|
|50011||File Contains Production Data for Test Environment||The referenced file was received in a test environment with one or more records having a DocTypeIndic value in the range OECD0-OECD3.
These DocTypeIndic values indicate data in this file may have been intended as a valid CbC file submission. CbC messages received in test environments are not accepted by the receiving Competent Authority as a valid CbC file submission.Submissions to the test environment should only include records with DocTypeIndic in the range OECD10-OECD13, indicating test files.
|80002||CorrDocRefId unknown||The CorrDocRefId refers to an unknown record.|
|80003||CorrDocRefId no longer valid||The corrected record is no longer valid (invalidated or outdated by a previous correction message). As a consequence, no further information should have been received on this version of the record.|
|80004||CorrDocRefId for new data||The initial element specifies a CorrDocRefId.
(OECD1 with CorrDocRefId data)
|80005||Missing CorrDocRefId||The corrected element does not specify any CorrDocRefId.
(OECD2 or OECD3 submission without CorrDocRefId data)
|80006||DocSpec, CorrMessageRefID||The CorrMessageRefID is forbidden within the DocSpec_Type.|
|80007||MessageSpec. CorrMessageRefID||The CorrMessageRefID is forbidden within the Message Header.|
|80010||Message TypeIndic||A message can contain either new records (OECD1) or corrections/deletions (OECD2 and OECD3), but should not contain a mixture of both.|
|80011||CorrDocRefID twice in same message||The same CorrDocRefID cannot be corrected or deleted twice in the same message.|
3 July 2018
A fix for issues 855135 (Issue with validation rule VR.ATO.LCMSF.000083) and 855128 (Issue with validation rule VR.ATO.LCMSF.000087) will be deployed:
• Thursday 5 July – to the External Vendor Testing Environment (EVTE)
• Saturday 14 July – to production.
More information about these issues is available in the 2018 CbC Reporting Package, located on the sbr.gov.au Significant global entity obligations page.
26 June 2018
The 2018 CbC Reporting Package has been updated to include sample messages based on the 2018 Local File / Master File (LCMSF) schema. The package is located on the sbr.gov.au Significant global entity obligations page.
The 2018 LCMSF service has been deployed into the External Vendor Testing Environment (EVTE) for Bulk Data Exchange (BDE) and SBR. Conformance suites are available via the SBR Share File (login required).
5 June 2018
The Significant global entity obligations (SGEO) page on sbr.gov.au has been updated with technical documentation relating to the 2018 Local File / Master File (LCMSF) service. The update relates to changes to the form validation rules.
18 May 2018
Updated technical documentation relating to the 2018 Local File / Master File (LCMSF) service is now available via the Significant global entity obligations (SGEO) page on sbr.gov.au.
24 April 2018
The significant global entity obligations (SGEO) page on sbr.gov.au has been updated with technical documentation relating to the 2018 Local File / Master File (LCMSF) service. The documentation includes the following initial draft documentation:
- Message Structure Table (MST)
- XML Schema (XSD)
- Validation Rules.
The XML schema has been generated using the latest ATO XML schema generation algorithm. For more information, refer to the ATO XML Schema Generation Algorithm (DOCX, 276KB) document on sbr.gov.au.
The 2018 service must be used for reporting periods starting on or after 1 January 2017. For the lodgments relating to earlier periods, you may use either the 2017 or 2018 service. The 2017 service cannot be used to lodge statements relating to reporting periods starting on or after 1 January 2017.
We anticipate the publication of the conformance suite and EVTE deployment will occur on 21 June 2018, with production deployment on 13 July 2018.
You can email any feedback or questions on the XML schema to the Cbc reporting mailbox.
Administrative Solution - Extended Time to Lodge
Given the EVTE will not be available until 21 June 2018, we are providing entities choosing to take up the administrative solution with additional time to lodge Part A of their Local file
The income tax return and relevant sections of the IDS must still be lodged by 16 July 2018, or the relevant due date. However, Part A of the Local file can be lodged up until 14 September 2018. Part A of the Local file must be received by 14 September 2018, to qualify for the administrative solution.
15 February 2018
Please see the significant global entity obligations (SGEO) page on sbr.gov.au for more information.
18 December 2017
All CbC files must contain the appropriate wrapper header for lodgment via Bulk Data Exchange (BDE) and Standard Business Reporting (SBR) channels.
14 July 2017
The final versions (v1.0) of technical documentation for the CbC report and Local File / Master File (LCMSF) service for 2017 are now available via the Significant global entity obligations (SGEO) page on sbr.gov.au.
The CbC reporting service has now deployed to production for both bulk data exchange (BDE) and SBR.
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 lodgment of the CbC report.
Links and documents
- Law Companion Ruling LCR 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
Feedback can be sent to CbCReporting@ato.gov.au.