From williambuck.com: On January 1, 2025, the ATO implemented stricter Country-by-Country reporting rules, significantly reducing the number of exemptions available to multinational enterprises.
MNEs must now file a local file, master file, and CbC report to comply, with limited exemptions covering specific cases like Australian-only operations or corporate restructuring.
The requirement for all Australian CbC reporting entities to submit a local file regardless of inter elated party dealings, introduces further compliance obligations and potential penalties for failure to adhere.