Country by Country Reporting – extended lodgement due dates

By Aileen O'Carroll - December 8, 2017

For the first reporting year, the Australian Taxation Office (“ATO”) has issued an extension of time for significant global entities (“SGEs”) to lodge their Country by Country (“CbC”) statements.

SGEs that are December and January balancers will have until 15 February 2018 to lodge CbC Statements.  This includes the Local File, Master File and CbC report as applicable under the law.  Failure to lodge penalties will not apply to statements that are lodged by 15 February 2018.

Are you a Significant Global Entity?

CbC reporting obligations apply to Australian taxpayers who are SGEs.  You are an SGE if you are:

  • a global parent entity whose annual global income (total of the income amount(s) of the consolidated group) is AUD1 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 AUD $1 billion or more.

Yes, I am a significant global entity

As an SGE, you must indicate this on your 2016-17 income tax return (under the International Dealings Schedule).  In addition to existing reporting requirements SGEs need to be aware of the following mandatory reporting obligations:

  • CbC reporting obligations which apply to income years commencing on or after 1 January 2016; and
  • Provision of general purpose financial statements, effective for income years beginning on or after 1 July 2017.

Due date for Lodgement

An SGE will be required to lodge CbC statements within 12 months after the close of the income year.  Accordingly, for December and January balancers the CbC report, Master File and Australian Local File are due to be lodged by 31 December 2017 and 31 January 2018, respectively.

Extension of time

The ATO has just released an internal statement that as the due date of 31 December 2017 falls within the closedown period, the ATO has made a decision to grant an extension of time to lodge CbC statements.  For the first reporting year, taxpayers with a 31 December 2016 and 31 January year end will have until 15 February 2018 to lodge their CbC statements - the Local File, Master File and CbC report as applicable under the law.  

ATO officials are currently working to ensure that this deferred due date is reflected in their systems. However, if you or your tax agent receives an auto-generated letter regarding your CbC statements, you are advised to disregard the letter by the ATO.


Penalties for non-compliance with CbC reporting obligations can be as high as AUD $525,000.  However, no penalties would be applicable to CbC statements that are lodged by 15 February 2018 under the extension granted by the ATO.

What are the next steps?

December and January balancers should consider where they are with respect to meeting their CbC filing requirements and contact their Pitcher Partners representative to determine what action (if any) is required well before 15 February 2018.

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