As the 2026 financial year end rapidly approaches, multinational groups with a 30 June year‑end are now within two months of their first Public Country‑by‑Country (CbC) reporting deadline. Failure to lodge the Public CbC report on time may result in significant ATO penalties of up to AU$825,000, underscoring the importance of timely and proactive preparation.

The Australian Taxation Office has now released the final instructions and implementation guide for Public CbC reporting, providing much‑needed clarity on the information to be disclosed and the practical requirements for preparing and lodging the report.

A reminder on timing and scope

Public Country‑by‑Country (CbC) reporting is required to be lodged within 12 months after the taxpayer’s year end. Reports will be submitted to the Australian Taxation Office (ATO) and subsequently published on the Australian Government’s data.gov.au website, making the information publicly accessible.

Importantly, Public CbC reporting is a separate and distinct obligation from your existing confidential CbC reporting requirements. Compliance with one regime does not satisfy the other, and both obligations must be considered independently.

The Public CbC reporting requirement applies to multinational groups that meet all of the following criteria during the reporting period:

  • Global annual income of A$1 billion or more
  • Australian‑sourced aggregated turnover of at least A$10 million
  • An Australian resident group member, or a foreign resident operating through an Australian permanent establishment, at any time during the period

The reporting obligation rests with the global parent entity, referred to as the Public CbC reporting parent, rather than the Australian subsidiary.

What is different this time?

While many of the quantitative disclosures will be familiar to groups already preparing confidential CbC reports, there are two key features that materially change how groups should approach the Public CbC reporting compliance.

  • Public disclosure and reputational risk

Public CbC information will be permanently accessible to investors, regulators, the media and other stakeholders. This elevates the exercise beyond technical tax compliance and requires careful coordination with governance, legal, sustainability and communications teams to ensure messages are accurate, consistent and aligned with broader stakeholder expectations.

  • The new “approach to tax” statement

Groups must publish a qualitative statement describing their approach to tax, aligned with the GRI 207: Tax 2019 standard. This is a new requirement for many groups and will often involve articulating tax governance, risk management and engagement with tax authorities in a way that has not previously been done publicly.

Australia’s Public CbC regime is broader in scope and deeper in content than comparable regimes globally, driven in particular by this enhanced tax transparency narrative requirement, for example the approach to tax statement and related party revenues are not required in the European reporting regime.

The Australian regime also underscores the Government’s commitment to strengthening multinational tax transparency under the global ESG reporting framework .  HLB is also supporting clients with their ESG obligations in respect of mandatory climate related financial disclosures under AASB S2.

Exemptions and ATO engagement

As noted in our previous article, the ATO may grant full or partial exemptions from Public CbC reporting in limited circumstances set out in PS LA 2025/2. We anticipate that exceptions are to be granted only in exceptional cases, such as having impact on national security, breach of laws and disclosure of sensitive information.

Any group considering an exemption should engage with the ATO early, particularly in light of the first lodgement deadline is 30 June 2026.

What should groups be doing now?

With first lodgements approaching, in‑scope groups should be focusing on:

  • reconfirming whether they are in scope and identifying the Public CbC reporting parent;
  • agreeing internally (and with the global parent) who is responsible for preparing and lodging the report;
  • assessing whether any exemption may be relied on and engaging with the ATO where appropriate;
  • finalising their work on the GRI 207 approach to tax statement; and
  • planning for public release of the data and related stakeholder communications.

How HLB can help

HLB’s international team can assist at all stages of the Public CbC reporting process, including scope and threshold analysis, coordination with global parents, drafting GRI 207 tax strategy statements, XML report preparation and lodgement, exemption assessments and communications planning ahead of public disclosure.

If you would like to discuss how these requirements apply to your group, please contact your HLB adviser.