Last week, both houses of Parliament passed a tax Bill to implement the previously announced measures affecting significant global entities (SGEs) (broadly those with group turnover greater than $1 billion):
multinational anti-avoidance law (MAAL) to apply to foreign multinationals generating certain profits earned from Australia without an Australian permanent establishment;
domestic statutory requirements for country by country (CbC) reporting and additional local and master file transfer pricing documentation requirements
doubled tax penalties for larger companies in various situations, with application to income years commencing on or after 1 July 2015.
However, in order to secure support for the passage of the Bill, the Government controversially agreed to two extra amendments sponsored by the Greens (without further public consultation):
SGEs that are Australian resident or foreign resident with an Australian permanent establishment, will be required to lodge 'general purpose' financial statements (GPFS) with the ATO and ASIC for income years starting from 1 July 2016;
Limiting a recently-introduced exemption that protected majority Australian-owned private companies’ tax information from ATO public reporting starting with the upcoming mid-December ATO disclosures. Exemption will be limited to those private companies with revenue under $200 million.
