ATO offers lodgment deferral for CBC reporting
The Tax Office has announced an extension of the lodgment deadline for country-by-country reporting entities until 31 January 2025.
In a recent update, the Tax Office has stated that country-by-country reporting entities will have an automatic deferral until the end of January next year.
"If you're a country-by-country reporting entity that has reporting obligations for the period ending on 31 December 2023, an automatic lodgment deferral applies until 31 January 2025," the ATO said.
"This deferral applies to local files, master files and CBC reports due to be lodged by 31 December 2024, including those that have a replacement reporting period ending on 31 December 2023."
The ATO said that as the lodgment deferral automatically applies, a separate request for the deferral is not required.
However, the ATO has urged entities to ensure their CBC reporting statements were lodged by 31 January 2025 to avoid penalties.
CBC reporting was introduced as part of the OECD's base erosion and profit shifting (BEPS) project.
It applies to entities that were either a CBC-reporting entity or a significant global entity for a period prior to the income year.
An entity is a CBC reporting entity if it is either:
- A CBC reporting parent, which can be a standalone entity whose annual global income is $1 billion or more, or a member of a CBC reporting group that is not controlled by another entity in the group and has an annual global income A$1 billion or more.
- A member of a CBC reporting group and one of the other group members is a CBC reporting parent.
As part of CBC reporting requirements, entities must provide the ATO with three statements that include the CBC report, master file and local file.
"These statements disclose information that is relevant to your transfer pricing and BEPS-related risk profile," the ATO said.
"These include your global and local operations and activities, transfer pricing policies, international related party dealings, revenues, profits, and taxes paid."
The CBC reporting statements must be lodged through one of three channels including online services for business through file transfer, online services for agents through file transfer, or standard business reporting through SBR-enabled software.
"When you lodge CBC reporting statements through one of the appropriate channels, you will receive a message from the channel indicating that your lodgment has been successfully submitted," the ATO said.
The ATO said in most cases the CBC report will be filed in the jurisdiction of a multinational group’s CBC reporting parent and automatically exchanged with tax authorities in other jurisdictions in which the group operates.
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