In June 2016, the Australian Taxation Office (ATO) finalised the Local File requirements for Country-by-Country (CbC) Reporting in Australia. The Australian Local File requires specific transfer pricing and business information (e.g. local business strategy) to be prepared and reported in a standardised format that will need to be electronically lodged to the ATO.
There is a ‘two tiered’ approach to the Local File:
- Short Form Local File – available for taxpayers with very small Australian operations and immaterial international related party dealings (IRPDs) that need to satisfy very specific requirements to be eligible
- (Full) Local File – all other SGEs ineligible for the Short Form Local file will need to complete a (full) Local File which will need to contain all of the Short Form Local file requirements as well as Part A (detailed IRPDs for the income year similar to the IDS) and Part B (copies of agreements, advance pricing arrangements (APAs), TP methods and financial statements for all material IRPDs)