Australia Public Country-by-Country Reporting: 382 Multinationals Revealed

Last updated: November 2026 · Regulatory Status: Confirmed

Where do multinational groups earn their profits, and where do they actually pay tax? On 12 November 2026, Australia became one of the first countries to answer that question in public. The Australian Taxation Office (ATO) released the first 382 reports under Australia's public country-by-country reporting regime, exposing the jurisdictional tax footprint of the world's largest groups operating in Australia.

The release covers 201 Australian-headquartered and 181 foreign-headquartered multinational groups, according to the joint media release from the Assistant Treasurer and the Assistant Minister for Productivity. If your group earns A$1 billion or more globally and has a footprint in Australia, your tax data is now, or soon will be, open to investors, journalists and competitors.

At a glance: Australia's public CbC reporting regime

Attribute	Detail
Status	In force; first public reports released 12 November 2026
Legal basis	Taxation Administration Act 1953, as amended by the Treasury Laws Amendment Act 2024 (Schedule 4)
Applies to	Reporting periods starting on or after 1 July 2024
Global threshold	Annual global income of A$1 billion or more
Australian nexus	Relevant Australian-source income amounts totalling A$10 million or more, subject to statutory conditions and exemptions
Lodgement deadline	Within 12 months after the end of the reporting period
Jurisdictional detail	Australia + 40 specified jurisdictions individually; others may be aggregated
First release	382 groups (201 Australian-HQ, 181 foreign-HQ), mainly 30 June year-ends
Next release	May 2027, including many foreign-headquartered groups
Official portal	ATO – Public country-by-country reporting

What did the ATO publish on 12 November 2026?

The ATO published 382 public country-by-country reports from large multinational groups. Each shows revenue, profit, income tax, employees and tangible assets for Australia and 40 specified jurisdictions, with the rest of the world reported in aggregate. Most reports come from groups with a 30 June financial year-end.

The split is close to even: 201 groups are headquartered in Australia and 181 abroad. That balance matters. Foreign-headquartered groups are usually already subject to confidential CbC reporting at home, but most have never had their jurisdictional numbers placed in the public domain by a tax authority.

In announcing the release, Assistant Treasurer Daniel Mulino framed it as a test of public confidence that the rules are being applied fairly. Assistant Minister Andrew Leigh was blunter, noting that multinational profits can travel halfway around the world without a suitcase.

Who must file a public country-by-country report in Australia?

A group's reporting parent may need to file where it meets the A$1 billion annual global income threshold and the group's relevant Australian-source income amounts total at least A$10 million, subject to other statutory conditions and exemptions. The obligation applies to reporting periods starting on or after 1 July 2024, and the report is due within 12 months of year-end.

In practice, the A$1 billion threshold sits below the EUR 750 million used for OECD BEPS Action 13 reporting, so some groups outside other public regimes are caught in Australia. The A$10 million test also counts Australian-sourced amounts earned by non-resident group members, so relying on the carve-out requires careful analysis. For background on how the regime reached Parliament, see our earlier report on Australia's public country-by-country reporting legislation.

Typical deadlines:

Year-end	Public CbC report due
30 June 2025	30 June 2026
30 September 2025	30 September 2026
31 December 2025	31 December 2026
31 March 2026	31 March 2027

What information is disclosed?

For Australia and each specified jurisdiction, groups disclose their main business activities, number of employees, revenues, profit or loss before income tax, income tax paid and accrued, and tangible assets. For all other jurisdictions, groups can report on a country-by-country basis or in aggregate.

The 40 specified jurisdictions are set out in the Taxation Administration (Country by Country Reporting Jurisdictions) Determination 2024. They include financial and holding-company centres such as Singapore, Switzerland and Hong Kong. This is where the regime has teeth: the low-tax hubs most often linked to profit shifting cannot be hidden in an aggregate line.

Why does public country-by-country reporting matter?

Public country-by-country reporting lets anyone test whether a group's reported profits and tax payments line up with where its people, assets and revenues are. Investors, NGOs, journalists and competitors can now run that comparison without access to confidential tax filings.

A group reporting high profits in a low-tax jurisdiction with few employees or tangible assets is likely to draw questions, as recent coverage of Apple's Singapore tax position shows. Such a mismatch does not in itself prove tax avoidance. Legitimate reasons include intangible ownership, regional headquarters, financing functions, timing differences and tax incentives. But the burden of explanation has shifted: the numbers are public first and the context comes later, if at all.

What does this mean for multinational tax departments?

Public CbC data turns transfer pricing and tax governance into a reputational issue. Tax teams now need a consistent, defensible story linking jurisdictional profits, economic substance and effective tax rates, aligned with what the group already says in financial statements, sustainability reports and Pillar Two filings.

Three risks stand out:

• Consistency risk. The same group now reports overlapping data in the confidential OECD CbC report, Pillar Two GloBE returns, EU public CbCR and Australia's public report. Each uses different rules, so the numbers will not always match, and analysts will notice.

• Audit risk. Public data hands tax authorities in other countries, and their media, a ready-made risk-assessment tool. Expect it to feed into transfer pricing reviews and audit selection, alongside other cross-border rules such as the US BEAT regime.

• Narrative risk. A raw table cannot explain why a Singapore hub earns high margins. Groups that do not prepare explanatory commentary leave interpretation to others.

How does Australia's regime compare with OECD and EU reporting?

Australia's regime goes further than both. OECD CbC reports under BEPS Action 13 are confidential and shared only between tax authorities. The EU public CbCR Directive (EU) 2021/2101 is public but applies a EUR 750 million threshold and a narrower jurisdiction list.

Feature	OECD CbCR (BEPS Action 13)	EU public CbCR	Australia public CbCR
Public?	No	Yes	Yes
Revenue threshold	EUR 750m	EUR 750m (two consecutive years)	A$1bn + A$10m Australian-source income
Country-level detail	All jurisdictions	EU states + EU tax blacklist/greylist	Australia + 40 specified jurisdictions
Published by	Not published	Company (website / business register)	ATO, on a government website

The last row is the practical difference. In Australia, the tax authority itself publishes the data in one place, which makes cross-company comparison far easier.

What happens next?

The November 2026 release mainly covers groups with June year-ends. Further reports, including many from foreign-headquartered multinationals, are expected in May 2027. That second wave will bring many of the largest US and European groups into public view.

6 steps to prepare for public CbC scrutiny

1. Confirm scope. Test the A$1 billion global income threshold and the A$10 million Australian-source income test for every reporting period, including Australian-source income of non-resident group members.

2. Map the deadlines. Diary the 12-month lodgement date for each year-end and build in time for review and sign-off.

3. Reconcile your datasets. Compare figures across the OECD CbC report, Pillar Two GloBE information return, EU public CbCR and the Australian public report, and document why they differ.

4. Stress-test the specified jurisdictions. Review profit, headcount and assets for each of the 40 specified jurisdictions, starting with low-tax hubs, and check that transfer pricing documentation supports the outcome.

5. Prepare the narrative. Draft short explanatory notes for any jurisdiction where profit looks out of line with substance, ready for investors, media and the board.

6. Benchmark your peers. Download competitors' published reports from the ATO data release and see how your effective tax rates and profit allocation compare.

Frequently asked questions

What is public country-by-country reporting in Australia?

It is a regime requiring large multinational groups to publish selected tax information country by country for Australia and 40 specified jurisdictions, with aggregation permitted for other jurisdictions. The ATO collects the reports and publishes them on a government website. It applies to reporting periods starting on or after 1 July 2024 and builds on the confidential OECD CbC reporting rules.

What is the threshold for Australian public CbC reporting?

A group's reporting parent may need to report where it meets the A$1 billion annual global income threshold and the group's relevant Australian-source income amounts total at least A$10 million in the reporting period, subject to other statutory conditions and exemptions. Groups below the A$10 million Australian-source figure are generally exempt, even if they exceed the global threshold.

When is the Australian public CbC report due?

The report must be given to the ATO within 12 months after the end of the reporting period. For a 30 June 2025 year-end, it was due by 30 June 2026. For a 31 December 2025 year-end, it is due by 31 December 2026.

Which jurisdictions must be reported separately?

Australia and 40 specified jurisdictions listed in the Taxation Administration (Country by Country Reporting Jurisdictions) Determination 2024, including Singapore, Switzerland and Hong Kong. Information for all other jurisdictions can be reported country by country or as one aggregated figure.

Does a high profit in a low-tax country mean a company is avoiding tax?

Not necessarily. Differences between profit and substance can reflect intangible ownership, regional headquarters, financing activities, timing or legitimate tax incentives. Public CbC data flags where questions may be asked, but it does not by itself establish tax avoidance.

When will the next public CbC reports be published?

The Australian Government expects further reports, including many from foreign-headquartered multinationals, to be published in May 2027.

Conclusion

The bigger question for every international tax function is whether public tax transparency is now as important as tax compliance itself. With Australia's public country-by-country reporting live, the answer for groups in scope is increasingly yes.

Official sources: Australian Treasury – joint media release, 12 November 2026 · ATO – Public country-by-country reporting · Directive (EU) 2021/2101

Need help preparing for public CbC scrutiny? Find transfer pricing and international tax advisers in the TaxSpoc Directory.