Written by Camila Weinstein – Tax Associate
Corporate tax transparency is undergoing a global shift. Once treated as a technical compliance obligation, tax disclosure has become a visible indicator of governance quality, corporate integrity and social responsibility. Investors, regulators and the public increasingly expect companies not only to comply with tax laws, but to clearly explain how and where they contribute to public finances.
Australia is now firmly positioned at the forefront of this shift. Two major developments are reshaping the local transparency landscape: the introduction of Public Country-by-Country (CbC) reporting and the redesign of the Voluntary Tax Transparency Code (VTTC). Together, they signal a move from minimum compliance to proactive, public accountability.
For multinational enterprises with an Australian presence, tax transparency is no longer just a tax issue, it is a governance, ESG and reputational priority.
From Compliance to Public Accountability
Globally, tax transparency is increasingly linked to ESG frameworks and stakeholder trust. Governments are strengthening disclosure regimes, investors are embedding tax integrity into ESG assessments, and communities expect clearer insight into how multinationals generate profits and pay tax.
In Australia, these pressures are reflected in heightened scrutiny from the Australian Taxation Office (ATO) and growing expectations from investors and the public. Tax disclosures are now public-facing statements that can influence reputation and confidence, not just regulatory filings.
The introduction of Public CbC reporting is a key example of this shift.
Public Country-by-Country Reporting: A New Disclosure Regime
On 29 November 2024, the Australian Parliament passed legislation introducing a Public Country-by-Country reporting regime, delivering on the Government’s commitment to greater transparency.
Under the new rules, large multinational groups that are CbC reporting parent entities with AUD 10 million or more of Australian-sourced turnover must publicly disclose detailed financial and tax information on a jurisdiction-by-jurisdiction basis.
The regime applies to income years beginning on or after 1 July 2024, with the first reports due by 30 June 2026. While this may appear some time away, the scale and sensitivity of the required disclosures mean early preparation is critical.
What Will Be Disclosed – and Why It Matters
Unlike traditional CbC reporting, which is shared privately with tax authorities, Australia’s regime makes this information publicly available. This significantly increases both scrutiny and risk.
Disclosures will include revenue, profits, income tax paid and accrued, employee numbers, tangible assets and descriptions of business activities for Australia and specified foreign jurisdictions. Groups must also provide narrative explanations of tax outcomes, including differences between expected and actual tax results.
Importantly, the regime adopts GRI 207: Tax as a reference framework, explicitly linking tax transparency with ESG reporting. This reinforces the expectation that tax outcomes should align with economic substance and stated corporate values.
For many groups, this will be the first time such granular tax information is exposed to investors, media and the broader public.
ATO Guidance Signals a Highly Structured Approach
Draft instructions released by the ATO indicate a tightly controlled reporting framework. Reports must be lodged in a prescribed XML format, reconcile to audited consolidated financial statements and include a clearly articulated “approach to tax”.
The ATO has also identified a broad list of jurisdictions requiring individual reporting, increasing the level of granularity compared to other international regimes. Exemptions will be limited and only available with express ATO approval.
From a governance perspective, these requirements underscore the need for robust internal controls, consistent data and careful coordination across tax, finance and reporting teams.
Governance and Reputational Implications
Public CbC reporting elevates tax from a back-office function to a board-level issue. Once published, reports can be analysed and interpreted by stakeholders with varying levels of technical expertise.
This raises important questions for organisations, including:
- Are tax outcomes consistent with ESG commitments and public messaging?
- Is the group prepared to explain its effective tax rate publicly?
- Are disclosures consistent across jurisdictions and reporting frameworks?
- Do governance and control frameworks support public scrutiny?
Clear explanations and strong internal alignment will be essential to manage reputational risk.
Redesign of the Voluntary Tax Transparency Code
Alongside Public CbC reporting, Australia is modernising its voluntary transparency framework. The Voluntary Tax Transparency Code, first introduced in 2016, has been redesigned to reflect evolving global standards and increased community expectations.
The updated VTTC applies to income years starting on or after 1 July 2026, with early adoption encouraged. It places greater emphasis on explaining how tax outcomes arise, rather than simply reporting figures.
Key changes include stronger alignment with GRI 207, a clearer focus on tax governance and risk management, and differentiation between entities subject to Public CbC reporting and those that are not. The redesigned framework also seeks to reduce duplication while encouraging consistent, meaningful disclosures.
Managing Overlap and Consistency
With multiple transparency regimes now in play, Public CbC reporting, ATO corporate tax disclosures, sustainability reporting and the VTTC, consistency has become a critical challenge.
Even technically correct disclosures can create confusion if they appear inconsistent across different reports. Leading organisations are responding by taking a holistic approach, aligning tax narratives across regulatory, ESG and voluntary disclosures.
What Multinationals Should Be Doing Now
Although first Public CbC reports are not due until 2026, preparation should begin now. Key steps include assessing data readiness across jurisdictions, reviewing governance and control frameworks, developing a clear tax strategy narrative and coordinating early between tax, legal, finance and communications teams.
Early action not only reduces compliance risk, but also allows organisations to shape their tax narrative rather than react to scrutiny later.
Final Thoughts
Australia’s Public CbC regime and redesigned VTTC reflect a decisive shift toward transparency as a core element of corporate accountability. For multinational enterprises, tax is no longer just about compliance, it is about trust, governance and long-term value.
Those that prepare early and take a strategic approach will be best placed to navigate this new era of public tax transparency.
Harris Gomez Group METS Lawyers ® opened its doors in 1997 as an Australian legal and commercial firm. In 2001, we expanded our practice to the international market with the establishment of our office in Santiago, Chile. This international expansion meant that as an English speaking law firm we could provide an essential bridge for Australian companies with interests and activities in Latin America, and to provide legal advice in Chile, Peru and the rest of Latin America. In opening this office, HGG became the first Australian law firm with an office in Latin America.
As Legal and Commercial Advisors, we partner with innovative businesses in resources, technology and sustainability by providing strategy, legal and corporate services. Our goal is to see innovative businesses establish and thrive in Latin America and Australia. We are proud members of Austmine and the Australia Latin American Business Council.
Disclaimer: This article is for general informational purposes only and does not constitute legal advice. It does not create a solicitor-client relationship, and readers should seek independent legal advice for their specific circumstances. Harris Gomez Group accepts no liability for reliance on this content.