Public CbCR Guidance

The Australian Taxation Office (ATO) has introduced Public Country by Country Reporting (Public CbCR), that requires certain large Multinational Enterprises (MNEs) to publicly disclose tax and financial information for every country in which they operate, published on a publicly accessible government website.

Eligibility
Large MNEs must lodge Public CbCR if it meets 3 main conditions, these are summarised in the figure below:

Note: Public CbCR is separate from OECD CbCR^{^[1]}and involves different reporting eligibility criteria and obligations.
[1] https://www.ato.gov.au/businesses-and-organisations/international-tax-for-business/in-detail/pricing/transfer-pricing/country-by-country-reporting

Due Dates

Public CbCR applies to reporting periods starting on or after 1 July 2024 due within 12 months after the end of the reporting period. This means the first Public CbCR lodgments will be for FY 30 June 2025.

Example: If your period ends 30 June 2025, the Public CbCR is due 30 June 2026.

Key Disclosure in Public CbCR

A Public CbCR’s key disclosures include:

Revenue
Profit or loss
Employees
Taxes paid and accrued
Main business activities; and
Other prescribed financial metrics.

How Does This Affect MNEs?

Increased compliance effort: Public CbCR requires detailed country level data not normally captured in standard finance systems. This increases demand on finance, tax, human resource, and compliance teams.
Greater public scrutiny: Because the report is publicly available, stakeholders such as media, investors, NGOs, and customers may analyse and comment on the MNE’s tax positions for all tax jurisdictions.
Need for consistency with other disclosures: Public CbCR may be compared with documents such as Annual financial statements, Sustainability / Environmental, Social, and Governance (“ESG”) reports, OECD CbCR, Transfer pricing documentation and Public announcements. Inconsistencies can create reputational or regulatory risk, so internal alignment is essential.

Next Steps

Determine if the group is in scope: Assess and document whether your entity meets the Public CbCR conditions
Conduct a data mapping exercise: Identify data required, gaps, and the owner of each data element
Develop and document reporting methodology of Public CBCR: Including the basis of preparation, currency conversion rules, treatment of branches, treatment of SAP entities[2], acquisitions, estimation techniques and all other assumptions applied
Prepare narrative explanations: Draft clear explanations of business activities per country, unusual outcomes, restructurings, or tax volatility
Strengthen governance controls: Because the report becomes public: Senior management review is essential; Legal, Finance, ESG, and Communications teams must be aligned; and Quality and audit controls should be enhanced
Assess reporting due dates and prepare early: A 12-month deadline can still be challenging if data is decentralised or incomplete.

[2] Substituted Accounting Period (“SAP”), an entity that does not use the standard 1 July – 30 June financial year

The introduction of Australia’s Public Country‑by‑Country Reporting regime represents a significant shift in how large multinational groups are expected to demonstrate tax transparency. Unlike OECD CbCR, Public CbCR requires detailed country‑level tax and financial information to be published on a government website, placing groups under increased regulatory, media and stakeholder scrutiny.

For in‑scope MNEs, the challenge extends well beyond data collection. Public disclosures must be internally consistent with transfer pricing documentation, statutory accounts, ESG reporting and public statements, with any misalignment potentially creating reputational or compliance risk. Early preparation, robust governance and a clearly documented reporting methodology are critical to managing the operational complexity and public exposure that come with this new reporting obligation.

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