Ref: AOC:np
28 April 2023
Director International Tax Branch Corporate and International Tax Division The Treasury Langton Cres PARKES ACT 2600 By Email: MNETaxTransparency@treasury.gov.au Dear Sir/Madam PUBLIC COUNTRY-BY-COUNTRY REPORTING 1.
Thank you for the opportunity to provide comments to Treasury in relation to the exposure draft legislation (“ED”) and explanatory memorandum (“EM”) relating to the proposed new tax transparency measures requiring certain entities to publish selected tax information for income years beginning on or after 1 July 2023.
2.
Pitcher Partners specialises in advising Australian taxpayers in what is commonly referred to as the middle market. Pitcher Partners often deals with clients subject to existing Country-by-Country reporting requirements and therefore these clients are also potentially impacted by the proposed new public Country-by-Country (“CbC”) reporting measures as described in the ED and EM.
3.
In general, we believe that the proposed measure unjustifiably departs from the public CbC reporting standards of other jurisdictions, in particular those currently being implemented by the European Union (“EU”). Disclosure requirements should be agreed globally, with future reporting requirements updated for all jurisdictions at the same time. The additional information proposed by Treasury is likely to significantly increase the compliance burden for reporting entities and is disproportionate to the benefit likely