The Australian Taxation Office (ATO) has published further guidance for taxpayers who are (or will be) subject to the Country-by-Country Reporting (CbCR) regime.
The guidance outlines how taxpayers can apply for a specific exemption from some or all the CbCR obligations and also the general principles the ATO will take into account in making its decision. It covers taxpayers that are Australian subsidiaries of overseas multinational enterprises (MNEs) as well as Australian-based MNEs.
This exemption guidance is part of a larger tranche of guidance that the ATO is releasing to assist taxpayers to comply with the CbCR regime.
Our key observations with respect to the guidance are:
Impacted taxpayers should consider their facts and circumstances and determine whether an exemption request would be appropriate, particularly given the potential to reduce compliance costs.