Australian Public CbCR: Key implications for MNEs with Singapore operations

Australia has introduced a new Public Country-by-Country Reporting (CbCR) legislation, which takes effect for financial years beginning on or after 1 July 2024. Under this regime, large multinational enterprise (MNE) groups with significant operations in Australia will be required to publicly disclose a range of tax and financial data on a jurisdiction-by-jurisdiction basis—including Singapore, which is on the list of specified jurisdictions subject to detailed disclosure.

Who is affected?

This applies to parent entities, independent of jurisdiction, of groups with:

• Annual global income of AUD 1 billion or more in the preceding period; and
• AUD 10 million or more in Australian-sourced income in the reporting period; and
• An Australian presence, e.g., Australian entity or branch.

Parent entities—regardless of where they are based—must submit the relevant data to the Australian Taxation Office (ATO) within 12 months of the reporting period end in an “ATO approved form”. The ATO will publish this information online.

What must be disclosed for Singapore?

Data must be reported on a standalone basis and includes:

1. The name of the entity.
2. Description of main business activities.
3. The number of employees (on a full-time equivalent basis) at the end of the reporting period.
4. Revenue from unrelated parties.
5. Revenue from related parties that are not tax residents of the jurisdiction.
6. Profit or loss before income tax.
7. Book value at the end of the reporting period of tangible assets, other than cash and cash equivalents.
8. Income tax paid (on a cash basis).
9. Income tax accrued (current year).
10. The reasons for the difference between income tax accrued (current year) and the amount of income tax due if the income tax rate applicable to the jurisdiction were applied to profit and loss before income tax.
11. The currency used in calculating and presenting the above information.

Amounts reported should be based on the figures shown in the audited consolidated financial statements or amounts that would be shown in such statements had the parent entity been a listed company within the meaning of Australian law and required to prepare such financial statements. Correction of material errors must be made within 28 days of discovering the error, and there is also a provision for correcting minor errors. A penalty of up to AUD 825,000 (based on the current value of penalty units) may be imposed for late or non-lodgement or failure to correct a material error.

Certain entities may be granted an exemption from filing by the ATO if it would affect national security, breach Australian law or the laws of another jurisdiction, or result in substantial ramifications for the entity (by an objective standard) by revealing commercially sensitive information. The ATO indicates on its website that it is planning on the release of a practice statement during 2025 outlining the approach to reporting exemptions, although these are generally expected to be limited.

How should Singapore MNEs prepare?

1. Data readiness: Consider similar reporting frameworks (e.g., Organization for Economic Cooperation and Development (OECD) CbCR, GRI 207, the European Union (EU) Public CbCR, and Pillar Two), aligning the data reported where possible. Centralise tax data sources and reconcile tax figures such as accrued vs. paid tax.
2. Stakeholder communication: Given the public nature of disclosures, MNEs should prepare messaging and engage with internal teams (e.g., Investor relations, Legal, and Communications) to align on narrative and disclosures.
3. Governance and strategy: The new rules require groups to disclose their approach to tax—making it vital to document tax governance, risk management processes, and oversight mechanisms. Singapore-based groups should ensure they have a clear and accessible Tax Policy aligned with the Inland Revenue Authority of Singapore (IRAS) Tax Governance Framework, GRI 207 or similar frameworks.

Interaction with EU Public CbCR

The EU’s Public CbCR requirements also apply to groups with EU operations and over EUR 750 million in global revenue. While Singapore is not on the EU’s list of non-cooperative jurisdictions, EU-based MNEs must still report by jurisdiction for EU Member States and affected third countries (e.g., Russia, Vietnam etc.).

Conclusion

Singaporean companies that are part of MNEs, as well as those headquartered in Singapore, should commence preparations immediately. The implementation of Australia's Public CbCR contributes to the increasing global emphasis on tax transparency. Affected groups must ensure data readiness, internal coordination, and policy alignment across all jurisdictions.

Deloitte offers help with external communication strategies, tax policy development, and mock reports, as well as preparation and submission of the public Country-by-Country report. For more information, please contact our Deloitte experts below.

Authors

• Michael Nixon – International Tax & Transfer Pricing Partner, Deloitte Singapore
• Andreas Kirsch – Tax Governance Group Director, Deloitte Singapore
• Rishi Mehrotra – International Tax & Transfer Pricing Director, Deloitte Singapore