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Australia Publishes Local File / Master File Detailed Design — Orbitax Tax News & Alerts

On 12 April 2017, the Australian Taxation Office (ATO) published the Local file / Master file detailed design. The Local and Master file requirements generally apply for income years beginning on or after 1 January 2016 for significant global entities (SGEs), which include entities that are part of an MNE group meeting an AUD 1 billion revenue threshold in the previous year.

The guidance expands upon the local file - high level design originally issued in July 2016 ({News-2016-07-13/A/2- previous coverage}) to provide details on the submission of the Local and Master files, which must be done using a prescribed XML Schema. The guidance is tailored towards software developers for the generation of a valid XML schema, but is also useful for taxpayers in general to understand what will need to go into meeting their Local and Master file obligations in Australia.  

The guidance also notes that the XML schema for Local and Master file includes certain questions regarding who will submit a Country-by-Country (CbC) report for the group (notification), but that the CbC report itself must be submitted separately in accordance with the OECD XML schema.

CbC statements, including CbC report, Master file, and Local file, must be submitted via one of the following ATO approved channels:

In no case will paper statements be accepted. Failure to submit in the approved form may result in penalties of up to AUD 525,000 (increased penalties for SGEs effective 1 July 2017 - {News-2017-03-17/A/2- previous coverage}).