ATO guidance for Public Country-by-Country Reporting exemptions finalised

The narrowness of the availability of an exemption continues to be evident, with a focus on establishing exceptional circumstances and substantial adverse ramifications, as highlighted by Sean Madden and Amanda Maguire.

The Australian Taxation Office (ATO) has finalised its guidance for ATO staff which must be considered when applying the Commissioner's discretion for granting an exemption from Australian public country-by-country (CbC) reporting obligations. Practice Statement Law Administration PS LA 2025/2 (the PS LA) is a finalisation of the draft guidance released earlier this year, PS LA 2025/D1. For background, the public CbC reporting rules provide discretion for the Commissioner to exempt an in-sc...

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Authors: Sean Madden, Amanda Maguire

Published Date: 11 December 2025