At a glance
#Dates are for an example year end of Jun 30, 2026. Where local law moves a deadline on a weekend or national public holiday to the next working day, the date shown is already moved. Use the Deadlines tool for your own year end and thresholds.
Verified 2026-09-30. Tax authority: Australian Taxation Office (ATO). Summaries are simplified; check the linked official source before relying on them.
The law
#Transfer pricing is in Division 815 of the Income Tax Assessment Act 1997: Subdivision 815-B (cross-border dealings between entities, ss. 815-100 to 815-150), 815-C (permanent establishments) and 815-D (partnerships and trusts). s. 815-135 requires the arm's length rules to be applied consistently with the OECD Transfer Pricing Guidelines. Documentation and penalty rules are in Subdivision 284-E of Schedule 1 to the Taxation Administration Act 1953. CbC reporting is in Subdivision 815-E of the ITAA 1997.
Documentation
#TP documentation is not compulsory, but without records that meet s. 284-250 TAA (prepared before the return is lodged, in English, explaining how Subdivision 815-B/C applies) a taxpayer cannot have a 'reasonably arguable position' for penalty purposes. Significant global entities (SGEs, annual global income of AUD 1bn or more) that are CBC reporting entities must lodge a Local File, Master File and CbC report with the ATO within 12 months after year end (s. 815-355 ITAA 1997). The Local File uses the ATO's own XML format (Part A transactions, Part B, plus OECD content); a short-form Local File is available in some cases. Simplified record keeping options exist for small taxpayers and low-risk dealings (PCG 2017/2).
Methods
#OECD Guidelines methods, choosing the most appropriate method (s. 815-125 'arm's length conditions'). The ATO can reconstruct transactions where independent parties would not have entered into them (s. 815-130).
Penalties
#Scheme shortfall penalty base for TP adjustments: 25% of the shortfall if no reasonably arguable position (RAP), 10% if there is a RAP and no avoidance purpose, 50% if avoidance purpose without RAP. Without s. 284-250 documentation there is no RAP. Penalties are doubled for SGEs without a RAP. Late lodgment of CBC statements by an SGE: failure to lodge penalty multiplied by 500 (from 1 July 2026 roughly AUD 182,000 per 28 days late, up to about AUD 910,000).
Pillar Two
#Australia applies the IIR and a domestic minimum tax (DMT) from fiscal years starting on or after 1 January 2024 and the UTPR from 1 January 2025. Groups lodge a GIR and a Combined Global and Domestic Minimum Tax Return, and pay, 15 months after year end, 18 months for the transition year. No separate registration is needed; the first lodgment creates the account.
Other rules
#APAs (unilateral, bilateral, multilateral) under PS LA 2015/4. Thin capitalisation (Division 820) uses a 30% of tax-EBITDA fixed ratio test for most entities from 1 July 2023, with debt deduction creation rules. No formal secondary adjustment rule. Reportable Tax Position schedule and International Dealings Schedule are lodged with the return. Public CbC reporting applies from periods starting 1 July 2024 to CbC parents of AUD 1bn groups with AUD 10m or more Australian-sourced turnover. Diverted profits tax (Subdivision 177J ITAA 1936) and the Multinational Anti-Avoidance Law also apply to SGEs. CbC notification (not required): Australia has no CbC notification. Each CBC reporting entity lodges the CbC report (or relies on an exemption) within 12 months.
Filings and deadlines
#| # | Filing | When | Who | Source |
|---|---|---|---|---|
| 1 | Company tax return The legal default in the annual lodgment instrument is 31 October for 30 June year ends and the 15th day of the 7th month for substituted accounting periods of full self-assessment taxpayers. Companies lodging through a registered tax agent get later dates under the 2026-27 lodgment program: 31 January 2027 for a large or medium company (income over AUD 10m) that was taxable last year, 28 February 2027 if it was not, and 31 March or 15 May 2027 for smaller companies. The site shows 31 January when extended dates are on. Large/medium tax is due 1 December (first day of the 6th month). Cross-checked: PwC Worldwide Tax Summaries (Australia, Corporate, Tax administration, last reviewed 1 September 2026) states the return is generally due by the 15th day of the seventh month after the income year, or a later date the Commissioner allows, with extra time possible when a registered tax agent lodges. | Extended: tax agent lodgment program, large or medium company (e.g. Feb 1, 2027); original due date Oct 31, 2026 (moved from Jan 31, 2027, a Sunday) | All companies. The date shown is the usual date for large and medium companies (taxable in the prior year), for example 31 January for a 30 June year end. | Taxation Laws (Requirement to Lodge a Return for the 2026 Year) Instrument 2026 (LI 2026/16) |
| 2 | International Dealings Schedule (IDS) Lodged as a schedule with the company tax return. Discloses dealing types, amounts and TP methods used. | With Company tax return (extended) (e.g. Feb 1, 2027); original due date Oct 31, 2026 (moved from Jan 31, 2027, a Sunday) | Required when international related party dealings in the year exceed AUD 2m (including loan balances and property transferred), and in some other cases (for example thin capitalisation or foreign interests). | ATO: International dealings schedule |
| 3 | Reportable Tax Position (RTP) schedule Lodged with the company tax return. Covers uncertain and reportable positions, which often include TP positions. | With Company tax return (extended) (e.g. Feb 1, 2027); original due date Oct 31, 2026 (moved from Jan 31, 2027, a Sunday) | Companies with total business income of AUD 250m or more, or AUD 25m or more and part of an economic group with AUD 250m or more. Not needed if the company has an annual compliance arrangement with the ATO. | ATO: How to get the RTP schedule 2026 |
| 4 | TP documentation for penalty protection (Subdivision 284-E) Records must exist before the return is lodged and be in English. Documents made after lodgment do not count. | With Company tax return (extended) (e.g. Feb 1, 2027); original due date Oct 31, 2026 (moved from Jan 31, 2027, a Sunday) | Optional for any taxpayer with cross-border related party dealings, but needed to have a reasonably arguable position. | ATO TR 2014/8 Transfer pricing documentation and Subdivision 284-E |
| 5 | Local File (CBC statement) Lodged with the ATO in its XML format within 12 months after the end of the income year (ITAA 1997 s. 815-355). A short-form Local File may apply. | 12 months after year end (e.g. Jun 30, 2027) | CBC reporting entities: members of a group whose global parent has annual global income of AUD 1bn or more. | ATO: Country-by-country reporting |
| 6 | Master File (CBC statement) Lodged within 12 months after year end. Often lodged once for the group by one Australian entity. | 12 months after year end (e.g. Jun 30, 2027) | CBC reporting entities (AUD 1bn annual global income). | ATO: Country-by-country reporting |
| 7 | Country-by-Country report (CBC statement) Within 12 months after the end of the income year (ITAA 1997 s. 815-355). Late lodgment: SGE failure to lodge penalty (x500). From 1 July 2026 a penalty unit is AUD 364, so the SGE penalty is AUD 182,000 for each 28 days late, capped at AUD 910,000. | 12 months after year end (e.g. Jun 30, 2027) | CBC reporting entities (AUD 1bn annual global income). Australian entities of foreign-parented groups can apply to the ATO for an exemption, for example where the report is exchanged from the parent's country. | ATO: Country-by-country reporting |
| 8 | Public CbC report Selected tax information is published country by country on an Australian Government website. Lodged with the ATO within 12 months after the end of the reporting period; the first reports were due by 30 June 2026. Enacted by the Treasury Laws Amendment (Responsible Buy Now Pay Later and Other Measures) Act 2024 (confirmed via EY tax alert, 4 December 2024). Significant penalties apply for late or missing reports. | 12 months after year end (e.g. Jun 30, 2027) | Groups with global consolidated revenue of AUD 1 billion or more in the prior year (including purely domestic Australian groups), unless Australian-sourced income is under AUD 10 million. Applies to financial reporting periods starting on or after 1 July 2024. | ATO: Public CBC reporting parent |
| 9 | GloBE Information Return Lodged with the ATO 15 months after year end, 18 months for the group's transition year (30 June 2026 for calendar 2024). If the GIR is lodged abroad, a foreign lodgment notification is made in the combined return instead. Failure to lodge penalties for significant global entities can reach AUD 910,000 (2,500 penalty units at AUD 364 from 1 July 2026), but the ATO will remit them for years starting by 31 December 2026 where the group acted in good faith. | 15 months after year end (e.g. Sep 30, 2027) | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years. | EY: ATO Pillar Two guidance and lodgment deferral (ATO site blocked) |
| 10 | Combined Global and Domestic Minimum Tax Return and payment One return covering the foreign lodgment notification, the Australian IIR/UTPR return and the DMT return, due on the GIR timetable. Tax is payable on the same date. For the first 30 June 2026 due date, the IIR/UTPR and DMT returns got an automatic deferral to 30 July 2026, but payment did not. IIR and DMT apply from fiscal years starting on or after 1 January 2024; the UTPR from 1 January 2025. | 15 months after year end (e.g. Sep 30, 2027) | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years. | EY: ATO Pillar Two guidance and lodgment deferral (ATO site blocked) |
Official texts
#- Income Tax Assessment Act 1997 Division 815 (transfer pricing) (CC BY 4.0 (Federal Register of Legislation))
- Taxation Administration Act 1953 Schedule 1 Subdivision 284-E (CC BY 4.0 (Federal Register of Legislation))