On 29 November 2024, two important developments occurred concerning the EU and Australian pCbCR regulations. While the EC has released the final Implementing Regulation for EU pCbCR; Australian Parliament has passed the legislation containing the Australian pCbCR rules.
final Implementing Regulation related to EU pCbCR Directive
Non-EU headquartered groups (including Swiss-headquartered Groups) are not required to use the template and electronic formats laid down by the regulation. For these groups, only requirement is to publish their reports in a machine-readable format when they present the report in their group website.It is important to note that non-EU headquartered groups are also allowed to use the common template and electronic format required for EU headquartered groups.
As equally important for Swiss-headquartered Groups, Australian Parliament has approved pCbCR rules for groups who has annual global income of more than AUD 1 billion and aggregated Australian sourced turnover for the income year of AUD 10 million.
This information will be publicly accessible on an Australian government website. The “specified jurisdiction” list (which have Switzerland among other jurisdictions), for which disaggregated country level pCbCR is required, is still to be finalized by administrative determination, which is expected to occur after Royal Assent in December 2024.
For a December reporting period, the year ending 31 December 2025 would be the first year subject to Australian public CBC reporting, with reporting due by 31 December 2026.
Please find the link to our PwC Tax Alert here.
Michaela Merz 