Considerations on non-calendar fiscal years: OECD CbCR, EU and Australian public CbCR, and Pillar Two

By Ragnar Baldursson, Jonas Knutsson and Shivangi Magan

Most published guidance on country-by-country (CbC) reporting and Pillar Two is written for groups with a calendar year. Groups with a different fiscal year must adapt it.

Most first-filing timelines assume a 31 December year-end. [1] Groups with another year-end therefore have different first years, deadlines and end dates for transitional relief.

This article sets out the key dates for each regime and the pitfalls to avoid.

OECD CbCR: everything follows the UPE’s consolidated year

BEPS Action 13 sets the Reporting Fiscal Year as the period the Ultimate Parent Entity (UPE) uses for its consolidated financial statements. [2] The alignment is “… and not to taxable years or to the financial reporting periods of individual subsidiaries”. [3] In practice, the CbC report’s period and filing deadline run from the UPE’s year-end.

What to keep in mind for OECD CbC reporting (CbCR):

•          Deadlines run from the UPE’s year-end, not from 31 December. The CbC report is due 12 months after the last day of the Reporting Fiscal Year. [4]

•          Notification dates vary. In the EU, the Directive on Administrative Cooperation as amended for CbC reporting (DAC4) requires notification by the last day of the Reporting Fiscal Year, but lets Member States extend this to the entity’s tax-return deadline for the preceding year. [5] For a non-calendar group, that local tax-return date can fall far from the group’s year-end. Outside the EU, the date is set by each jurisdiction.

•          The threshold looks back one year. The EUR 750 million test applies to the fiscal year immediately preceding the reporting year. [6]

•          Short years are a local-law question. If the preceding year was shorter than 12 months, the OECD lets the UPE’s jurisdiction (and, for local filing, each other jurisdiction) choose, including: use the actual revenue, annualise it, or prorate the threshold. [7] Results can therefore differ between countries. [8] The guidance is silent on a preceding year longer than 12 months. [9]

•          Subsidiaries with different year-ends. You can use each entity’s own fiscal year ending on (or within 12 months before) the group’s year-end, or recut every entity to the group’s year. [10] Both approaches are valid, but the method selected must be applied consistently. [11]

•          Changing the year-end. The CbC report follows the consolidated accounts, even for a shorter (6-month) or longer (18-month) transition period. [12] OECD guidance covers this: an entity can contribute one, several or zero 12-month periods, and a jurisdiction with no data gets a row of zeros in Table 1 (its entities still appear in Table 2) plus an explanation in Table 3. [13] Where the reporting year is not 12 months and the group uses entity year-ends, the entity years to include are those ending within the group’s reporting year.

•          The XML expects both dates. The OECD CbC XML Schema (v2.0) asks for the start and end date of the Reporting Fiscal Year; the message header holds the end date only. [14] In our experience, many systems default to a calendar year. Check that both dates show the actual Reporting Fiscal Year.

EU public CbCR: under the Directive’s minimum dates, some non-calendar groups report first

The Accounting Directive applies the public CbC rules at the latest from the first financial year starting on or after 22 June 2024. [15] For calendar-year groups, that is FY2025, with the report published by 31 December 2026. [16] Groups whose financial year ends between 21 June and 30 November report first: their first in-scope year started in 2024. Groups with a year-end between 31 January and 20 June report later than calendar-year groups, as the 31 March row in the table of the latest permitted start dates shows. [17] Some Member States start earlier than the Directive requires (see National start dates differ below).

What to keep in mind:

•          The threshold is not the OECD test. Consolidated revenue must exceed EUR 750 million on the balance sheet date for each of the last two consecutive financial years, and the report covers the latter of the two. [20] It is not a look-back to the preceding year only. The obligation ends only after two consecutive years below the threshold. [21]

•          Non-EU groups with EU subsidiaries or branches. A medium-sized or large EU subsidiary, or a qualifying EU branch, of a non-EU group must publish the report on the group’s ultimate parent, unless the parent publishes the report itself. [22] The threshold test, the reporting year and the 12-month deadline all follow the parent’s consolidated financial statements, not the subsidiary’s own financial year. [23] For a group with a 31 March year-end, the report for the year ending 31 March 2026 is due by 31 March 2027, even if the EU subsidiary closes on 31 December. Romania says so expressly; check the national transposition, especially for the first in-scope year. [24]

•          No proration rule. The Directive does not address financial years shorter or longer than 12 months. [25] The sources we reviewed do not show how Member States deal with this. Check the national transposition and national accounting law of each Member State concerned.

•          Template and iXBRL timing. The common template and machine-readable electronic reporting formats (Inline XBRL, iXBRL) in Implementing Regulation (EU) 2024/2952 apply to financial years starting on or after 1 January 2025. [26] A 30 June or 31 October group’s first in-scope year started in July or November 2024. That first report therefore falls outside the Regulation; check what national law required for it. The second report must follow the Regulation. Do not simply roll last year’s file forward.

•          National start dates differ. Sweden applies the rules from the first financial year beginning after 31 May 2024, with a threshold above SEK 8 billion. [27] A group with a 1 June to 31 May year therefore came into scope one year earlier than the Directive requires. Romania applies its rules from 1 January 2023; an entity with a non-calendar financial year applies them from the start of its first financial year beginning after that date. [28] Croatia applies them to financial years beginning on or after 1 January 2024. [29]

•          Jurisdiction lists are fixed per financial year. Which jurisdictions must be shown separately depends on the EU list of non-cooperative jurisdictions as at 1 March of the financial year (Annex I), and as at 1 March of both the financial year and the preceding financial year (Annex II). [30] For a non-calendar group, the relevant 1 March is the one inside its own financial year: for an April 2025 to March 2026 year, 1 March 2026. A short financial year, for example after a change of year-end, may contain no 1 March at all, and a long one may contain two. The Directive does not say which list applies in either case; check the national transposition. [31]

Australian public CbCR: the UPE’s reporting period governs

Australia’s public CbC regime applies to reporting periods starting on or after 1 July 2024. [32] The reporting period is the period of the group’s audited consolidated financial statements. [33]

For an EU-parented group, the Australian Public CBC report therefore runs on the EU parent’s consolidated accounting period, not on the Australian 1 July to 30 June income year. The Australian Taxation Office (ATO) requires the report to reconcile with the audited consolidated financial statements. [34]

This may be more burdensome than it first appears, as the entry test uses three different time anchors: [35]

•          Parent status: the previous period. The reporting entity must have been a CbC reporting parent for a period that includes all or part of the previous financial-statement period. [36]

•          Group membership and Australian presence: any time in the current period. The entity must be a member of a CbC reporting group, and the entity or another group member must be an Australian resident, or a foreign resident operating an Australian permanent establishment, at any time during the reporting period. [37]

•          The AUD 10 million threshold: the parent’s year, treated as an income year. The Australian-source amounts in the entity’s aggregated turnover are measured over its reporting period, as if that period were an income year, not over the Australian subsidiary’s own income year. [38]

What to keep in mind:

•          First period and deadline. [39]

–         30 June year-end: first period 1 July 2024 to 30 June 2025; report was due by 30 June 2026.

–         31 October year-end: first period 1 November 2024 to 31 October 2025; report due by 31 October 2026.

–         31 December year-end: first period 1 January 2025 to 31 December 2025; report due by 31 December 2026.

•          No rule for short or long periods. The Act sets no length for the reporting period: it is each period for which audited consolidated financial statements are prepared. [40] Neither the ATO instructions nor its implementation guide address short, long or changed accounting periods. [41] PS LA 2025/2 mentions transitional reporting periods only as a possible ground for an exemption. [42]

•          Exemptions are per period, and the bar is high. A full or partial exemption covers a single reporting period. [43] Citing the Explanatory Memorandum’s reference to exceptional circumstances, the ATO says the discretion is not to be exercised lightly: routine circumstances will rarely qualify, though they need not be unique. It prefers partial to full exemptions and gives compliance cost alone little weight. [44] It gives positive weight where exchange-rate movements bring into scope a group that is below its home regime’s public CbC threshold, and it addresses changes in ownership, including transitional reporting periods. [45] Apply early: the ATO cannot reconsider a decision once made (only judicial review remains), and the obligation to report stands until an exemption is granted. [46]

Pillar Two: the year in which a Fiscal Year begins drives dates and rates

The Fiscal Year under the Global Anti-Base Erosion (GloBE) Rules is the UPE’s consolidated accounting period, the same anchor as in OECD CbCR. [47] However, Pillar Two dates are mostly tied to Fiscal Years beginning on or after a date, or beginning in a calendar year. [48] For non-calendar groups, this shifts the timeline, as the table below shows (EU start dates and GIR deadlines; OECD safe harbour dates).

Each row is the same Fiscal Year in the sequence; the GloBE Information Return (GIR) deadline runs from the end of that year. Two caveats apply to Year 1. The QDMTT is optional, so its start date is set by domestic law. And the Transition Year is defined per jurisdiction, so a group that first comes into scope for a jurisdiction later can have a later 18-month year; domestic QDMTT law may differ. [57]

What to keep in mind:

•          The 18-month deadline is still ahead for some. For a July to June group, the first GIR is due 31 December 2026. Under the OECD’s common understanding on central filing for the 2024 Reporting Fiscal Year, jurisdictions will, where domestic law allows and its conditions are met, waive penalties or not enforce local filing before the relevant exchange deadline. The text is drafted around the 30 June 2026 deadline, but refers to the relevant deadline and contemplates non-calendar 2024 years. Confirm the position locally. [58]

•          Rates follow the year in which the Fiscal Year begins. The Transitional CbCR Safe Harbour rate is 15% for years beginning in 2024, 16% in 2025 and 17% in 2026 and 2027. A July 2025 to June 2026 year is therefore tested at 16%, not 17%. [59] Under the Model Rules, the transitional rates for the Substance-based Income Exclusion (SBIE) work the same way (9.8% / 7.8% for years beginning in 2024). [60]

•          The Transitional CbCR Safe Harbour was extended. Since the January 2026 Side-by-Side Package, it covers Fiscal Years beginning on or before 31 December 2027, excluding years ending after 30 June 2029. [61] Domestic transposition may lag: in Sweden, the extension was only proposed in October 2026. [62]

•          CbC data quality now has tax consequences. The safe harbour relies on a Qualified CbC Report based on Qualified Financial Statements. [63] If the safe harbour is not applied for a jurisdiction in a year, it is lost for that jurisdiction for good (“once out, always out”). [64] If a tax audit later finds it was applied incorrectly, the GloBE Rules apply for that year and every later year. [65]

•          The revenue threshold is always prorated. In CbCR, proration is a local choice. Under Pillar Two, the EUR 750 million test (2 of the 4 preceding Fiscal Years) is adjusted proportionally for any year that is not 12 months. [66] The look-back windows also differ. Reusing the CbCR conclusion can therefore give the wrong result.

•          A QDMTT may run on its own fiscal period. Since the OECD’s September 2026 guidance, a jurisdiction applying the local-accounting-standard option may require its QDMTT to be computed for a fiscal period that differs from the group’s Fiscal Year. The QDMTT Safe Harbour then removes GloBE top-up tax for the group’s year only if every QDMTT period that begins or ends in that year qualifies. If one does not, the QDMTT is allocated month by month, and the GloBE top-up tax is reduced by the amount allocated to the group’s year. Check each QDMTT jurisdiction’s period before relying on the safe harbour. [67]

•          Mixed year-ends inside the group. For subsidiaries with a different year-end, the GloBE computations follow the method used in the consolidated financial statements: either the subsidiary’s own year ending within the UPE’s year, or figures recut to the UPE’s year. [68] For an entity outside the consolidated financial statements, the GloBE Rules use its accounting period that ends during the UPE’s Fiscal Year. [69]

•          Watch out for the GIR template version. The January 2025 GIR applies to Fiscal Years beginning before 31 December 2025; the September 2026 GIR applies to Fiscal Years beginning on or after that date, although its clarifying notes on existing data points also apply to earlier years. [70] A July group therefore switches templates for its July 2026 to June 2027 year. The OECD’s October 2026 XML Schema user guide sets a separate date for exchanges between tax authorities: version 1.0 until 15 June 2028, version 2.0 from 25 June 2028. [71]

•          Local filing and exchange timing. In the EU, DAC9 requires a tax authority that receives a centrally filed GIR to exchange it within 3 months of the filing deadline (6 months for the first Reporting Fiscal Year), and not before 1 December 2026. [72] Local top-up tax returns, notifications and payment dates are set by domestic law. Check them per jurisdiction.

•          52/53-week years. Some OECD dates are set to accommodate these years: the Transitional UTPR Safe Harbour covers years ending on or before 3 January 2027, so a 53-week year ending 2 January 2027 still qualifies. [73] Domestic law may lag behind. Sweden’s rule, as enacted, requires the year to end before 31 December 2026. In October 2026 the Government proposed extending it to 52/53-week years ending before 4 January 2027, in line with the OECD date, with an option to apply the change to those earlier years. [74] Check the domestic position before relying on the OECD date.

•          Changing your year-end is uncharted territory. The OECD has said it will issue guidance on Fiscal Years longer than 12 months, including transition years from a change of year-end, [75] but, as at October 2026, has not done so. The Transitional UTPR Safe Harbour only covers years of 12 months or less, although the OECD treats a 53-week year as covered. [76] Domestic laws may differ, so check each jurisdiction before changing the year-end.

Common pitfalls

Below is a short, non-exhaustive list of pitfalls for non-calendar groups.

1.        Copying a calendar-year timeline. Most published timelines assume a 31 December year-end. Rebuild yours from your actual year-end, regime by regime.

2.        One threshold conclusion for three regimes. OECD CbCR looks at the preceding year (proration is a local choice), EU public CbCR looks at the last two years including the reporting year, and Pillar Two looks at 2 of the 4 preceding years with mandatory proration. [77]

3.        Missing the first EU or Australian publication. Non-calendar groups have deadlines that differ from the dates most guidance highlights, so they are easier to miss. [78]

4.        Using the EU subsidiary’s year-end for a non-EU group. Where a non-EU group’s EU subsidiary or branch publishes the EU public CbC report, it reports on the parent’s financial year and to the parent’s deadline, not its own. Check the national transposition. [79]

5.        Using the wrong transitional rate. Safe harbour and SBIE rates follow the calendar year in which the Fiscal Year begins, not ends, under the Model Rules. Check how your jurisdiction transposed art. 48 of the Pillar Two Directive. [80]

6.        Relying on pre-2026 safe harbour dates. The Transitional CbCR Safe Harbour window has been extended, and the Side-by-Side measures start from different dates. [81]

7.        Mixed year-ends inside the group. Subsidiaries with their own local year-ends need one consistent approach in CbCR, and must follow the consolidation method in Pillar Two. [82]

8.        Changing the year-end without checking all three regimes. A short or long transition year affects CbC tables, public CbC thresholds, EU jurisdiction lists, Pillar Two thresholds, safe harbour eligibility and filing deadlines. [83]

9.        Treating the CbC report as a compliance-only exercise. Under Pillar Two, CbC data drives safe harbour eligibility. A data error that means a jurisdiction should not have qualified can switch on the full GloBE Rules for that year and every later year. [84]

Final considerations

For non-calendar groups, the rules are the same, but the dates are not. Map each regime against your own year-end, check national start dates and thresholds, and treat your CbC data as Pillar Two data.

How is your group handling this in practice? We are happy to discuss it.

This Article reflects Aunetic's own view and understanding of the rules on OECD country-by-country reporting, EU public country-by-country reporting, Australian public country-by-country reporting and related Pillar Two matters, based on publicly available legislation, guidance and other sources as at 26 October 2026.

It is provided for general information and discussion purposes only. It does not constitute tax, legal, accounting or other professional advice, and it should not be relied upon as such. It does not address the specific circumstances of any company or group.

Tax legislation, administrative guidance and their interpretation change frequently and may differ between jurisdictions. Some developments may have occurred after the date of this presentation and are not reflected in it.

Before taking any action, you should obtain advice from a qualified adviser that takes your specific facts and circumstances into account.

Aunetic accepts no liability for any loss arising from the use of, or reliance on, the content of this presentation. Sharing this presentation does not create an advisory or client relationship.

© Aunetic 2026. All rights reserved.

[1] Our observation. By contrast, the OECD’s own first-filing timeline had a separate track for groups with a year-end other than 31 December: OECD, Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 – 2015 Final Report (OECD 2015) [hereinafter Action 13 Report], at para. 50.

[2] Action 13 Report, annex IV to ch. V, Country-by-Country Reporting Implementation Package, Model Legislation [hereinafter Model Legislation], at arts. 1(8) (“Fiscal Year”) and 1(9) (“Reporting Fiscal Year”).

[3] Action 13 Report, at para. 50.

[4] Action 13 Report, at para. 31; Model Legislation, at art. 5; art. 8aa(1) Council Directive 2011/16/EU of 15 February 2011 on Administrative Cooperation in the Field of Taxation and Repealing Directive 77/799/EEC, OJ L64 (2011) [hereinafter DAC (2011/16)], as inserted by Council Directive (EU) 2016/881 of 25 May 2016 amending Directive 2011/16/EU as regards Mandatory Automatic Exchange of Information in the Field of Taxation, OJ L146 (2016) [hereinafter DAC4 (2016/881)].

[5] Annex III, sec. II, points 3–4 DAC (2011/16), as inserted by DAC4 (2016/881) (with the option to extend to the tax-return deadline); cf. Model Legislation, at art. 3 (dates in brackets, i.e. optional); OECD, Guidance on the Implementation of Country-by-Country Reporting: BEPS Action 13 (OECD May 2024) [hereinafter CbC Guidance], at ch. 5, sec. 2, Q. 2.1.

[6] Action 13 Report, at para. 52; Model Legislation, at art. 1(3); annex III, sec. I, point 4 DAC (2011/16) (“Excluded MNE Group”).

[7] CbC Guidance, at ch. 4, sec. 3, Q. 3.2 (the list of options is not exhaustive).

[8] CbC Guidance, at ch. 4, sec. 3, Q. 3.2.

[9] CbC Guidance, at ch. 4, sec. 3, Q. 3.2 (addresses only a preceding year shorter than 12 months; Q. 3.3–3.4 concern the reporting year).

[10] Action 13 Report, at annex III to ch. V, sec. B (“Period covered by the annual template”); CbC Guidance, at ch. 4, sec. 3, Q. 3.4, Example 1.

[11] Action 13 Report, at annex III to ch. V, sec. B (“on a consistent basis”).

[12] CbC Guidance, at ch. 4, sec. 3, Q. 3.3 and Q. 3.4, Examples 2.a–2.c (6-month year) and 3.a–3.b (18-month year).

[13] CbC Guidance, at ch. 4, sec. 3, Q. 3.4 (points following Example 1; Example 2.b; Table 3 statements).

[14] OECD, Country-by-Country Reporting XML Schema: User Guide for Tax Administrations, Version 2.0 (OECD June 2019), at sec. III.a (ReportingEntity/ReportingPeriod/StartDate and EndDate); see also sec. I (MessageSpec/ReportingPeriod: end date only).

[15] Art. 48g Directive 2013/34/EU of the European Parliament and of the Council of 26 June 2013 on the Annual Financial Statements, Consolidated Financial Statements and Related Reports of Certain Types of Undertakings, OJ L182 (2013), as amended by Directive (EU) 2021/2101 of the European Parliament and of the Council of 24 November 2021 amending Directive 2013/34/EU as regards Disclosure of Income Tax Information by Certain Undertakings and Branches, OJ L429 (2021) [hereinafter Accounting Directive (2013/34) and Directive (2021/2101)]; recital 12 Commission Implementing Regulation (EU) 2024/2952 of 29 November 2024 laying down a Common Template and Electronic Reporting Formats for the Application of Directive 2013/34/EU as regards the Information to be Presented in Reports on Income Tax Information, OJ L, 2024/2952 (2 Dec. 2024) [hereinafter Implementing Regulation (2024/2952)]. Art. 2 Directive (2021/2101) sets only the transposition date (22 June 2023).

[16] Arts. 48g and 48d(1)–(2) Accounting Directive (2013/34).

[17] Art. 48g Accounting Directive (2013/34) (“at the latest”).

[18] Art. 48g Accounting Directive (2013/34).

[19] Art. 48d(1)–(2) Accounting Directive (2013/34).

[20] Art. 48b(1), first subpara. Accounting Directive (2013/34); contrast OECD, Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 – 2015 Final Report (OECD 2015), annex IV to ch. V, Country-by-Country Reporting Implementation Package, Model Legislation, at art. 1(3).

[21] Art. 48b(1), second subpara. Accounting Directive (2013/34).

[22] Art. 48b(4) and (5) Accounting Directive (2013/34); exception where the non-EU ultimate parent publishes a consistent report itself: art. 48b(6).

[23] Art. 48b(4), first subpara. (“as regards the latter of those two consecutive financial years”) and art. 48d(1) (“within 12 months of the balance sheet date of the financial year for which the report is drawn up”) Accounting Directive (2013/34).

[24] RO: Ordinul nr. 2.048 din 1 septembrie 2022 privind completarea reglementărilor contabile aplicabile operatorilor economici [Order No. 2048 of 1 September 2022 supplementing the accounting regulations applicable to economic operators], Monitorul Oficial nr. 878 (7 Sept. 2022), art. III 4 (2), as inserted by Ordinul nr. 1.730 din 7 iunie 2023 pentru reglementarea unor aspecte contabile, Monitorul Oficial nr. 559 (21 June 2023) (report “care să corespundă exercițiului financiar al societății-mamă finale, și nu propriului exercițiu financiar”).

[25] Arts. 48a–48h Accounting Directive (2013/34) contain no rule on financial years shorter or longer than 12 months.

[26] Art. 5 Implementing Regulation (2024/2952); art. 48c(4) Accounting Directive (2013/34).

[27] SE: Lag (2023:340) om offentliggörande av vissa stora företags inkomstskatterapporter [Act on the Publication of Income Tax Information Reports of Certain Large Undertakings], secs. 2–4 (“mer än 8 miljarder kronor”) and transitional provisions, point 2 (“tillämpas första gången för det räkenskapsår som inleds närmast efter den 31 maj 2024”).

[28] RO: Ordinul nr. 2.048 din 1 septembrie 2022 privind completarea reglementărilor contabile aplicabile operatorilor economici [Order No. 2048 of 1 September 2022 supplementing the accounting regulations applicable to economic operators], Monitorul Oficial nr. 878 (7 Sept. 2022), art. III(1)–(2), and arts. III 2 (1) (example: 1 April 2023 to 31 March 2024 as the first financial year) and III 4 (1) and (4) (non-calendar financial year: first report for a financial year “care începe ulterior datei de 1 ianuarie 2023”), inserted by Ordinul nr. 1.730 din 7 iunie 2023 pentru reglementarea unor aspecte contabile, Monitorul Oficial nr. 559 (21 June 2023).

[29] HR: Zakon o izmjenama i dopunama Zakona o računovodstvu [Act amending the Accounting Act], Narodne novine 82/2023 (20 July 2023), art. 19(3).

[30] Art. 48c(5), second subpara. Accounting Directive (2013/34).

[31] Art. 48c(5), second subpara. Accounting Directive (2013/34) refers only to “1 March of the financial year for which the report is to be drawn up” and “1 March of the preceding financial year”; it contains no rule for a financial year that does not include a 1 March.

[32] Sch. 4, item 4 AU: Treasury Laws Amendment (Responsible Buy Now Pay Later and Other Measures) Act 2024 (Cth), Act No. 138, 2024 [hereinafter Act No. 138, 2024]; ATO, Instructions to complete the Public CBC report (as at 22 Sept. 2026) [hereinafter ATO Instructions], Section A (“Reporting period start date”).

[33] Sec. 3D(2)(a) AU: Taxation Administration Act 1953 (Cth) (Compilation No. 226, 27 Aug. 2026) [hereinafter TAA 1953] (and sec. 3D(2)(b) where no audited consolidated financial statements are prepared).

[34] ATO Instructions, Overview (“Compilation requirement”).

[35] Sec. 3D(1)(b)–(e) TAA 1953.

[36] Sec. 3D(1)(b) TAA 1953; sec. 3D(7) TAA 1953 (meaning as in the Income Tax Assessment Act 1997).

[37] Sec. 3D(1)(c)–(d) TAA 1953.

[38] Sec. 3D(1)(e) TAA 1953.

[39] Sec. 3D(3) TAA 1953; sch. 4, item 4 Act No. 138, 2024; ATO Instructions, Overview.

[40] Sec. 3D(2)(a) TAA 1953 (“each period for which audited consolidated financial statements for the entity for the period are prepared”); no length requirement appears in secs. 3D–3DB TAA 1953.

[41] ATO Instructions; ATO, Public Country-by-Country (CBC) Report 2025 (PCBC.2.0) Business Implementation Guide, v. 2.0 (27 Feb. 2026).

[42] ATO, Law Administration Practice Statement PS LA 2025/2 Public country-by-country reporting exemptions (5 Dec. 2025) [hereinafter PS LA 2025/2], at para. 88.

[43] Sec. 3DB(5)–(7) TAA 1953 (“must only specify a single reporting period”); ATO Instructions, Overview (“An exemption only applies to the reporting period for which it is granted”).

[44] PS LA 2025/2, at paras. 19, 30–32 (“not to be exercised lightly”; circumstances “need not be unique”), 40–41 (partial exemption more likely to be appropriate than full) and 53 (compliance costs).

[45] PS LA 2025/2, at paras. 56, 83–85 and Appendix 1, Example 5 (currency fluctuation; exemption granted again for the subsequent period) and paras. 86–88 (changes in ownership, including transitional reporting periods); see also ATO, PS LA 2025/2EC Compendium (5 Dec. 2025), issue 26 (“Merger and acquisition events”).

[46] PS LA 2025/2, at paras. 101–103 and 110 (no reconsideration once decided; extension of time under sec. 388-55 of sch. 1 TAA 1953) and paras. 116–117 (no objection; judicial review in the Federal Court).

[47] OECD, Tax Challenges Arising from the Digitalisation of the Economy – Global Anti-Base Erosion Model Rules (Pillar Two) (OECD 2021) [hereinafter GloBE Model Rules], at art. 10.1 (“Fiscal Year”); OECD, Tax Challenges Arising from the Digitalisation of the Economy – Consolidated Commentary to the Global Anti-Base Erosion Model Rules (2026) (OECD 2026) [hereinafter GloBE Commentary (2026)], at ch. 10, para. 18.

[48] Art. 56 Council Directive (EU) 2022/2523 of 14 December 2022 on Ensuring a Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union, OJ L328 (2022) [hereinafter Pillar Two Directive (2022/2523)]; GloBE Model Rules, at art. 9.2; GloBE Commentary (2026), at annex A ch. 1, box 1.1, para. 2; annex A ch. 2 s. 4, box 7.4, para. 1; annex A ch. 5, box 5.1, para. 7. GIR deadlines run from the end of the Fiscal Year: GloBE Model Rules, at arts. 8.1.6 and 9.4.1.

[49] Art. 56, second subpara. Pillar Two Directive (2022/2523); GloBE Model Rules, at art. 10.1 (“Transition Year”); GloBE Commentary (2026), at annex A ch. 1, box 1.1, para. 2.

[50] GloBE Model Rules, at arts. 8.1.6 and 9.4.1; art. 51 Pillar Two Directive (2022/2523); GloBE Commentary (2026), at ch. 9, para. 32 (no due date before 30 June 2026).

[51] Art. 56, third subpara. Pillar Two Directive (2022/2523); GloBE Commentary (2026), at annex A ch. 4, box 4.1, para. 2; annex A ch. 1, box 1.1, para. 2 (“Transition Rate” (b)).

[52] GloBE Model Rules, at art. 8.1.6; art. 44(7) Pillar Two Directive (2022/2523).

[53] GloBE Commentary (2026), at annex A ch. 5, box 5.1, para. 7 and para. 27; UPE Safe Harbour box, para. 4 and para. 38; annex A ch. 2 s. 3, box 2.3, para. 8; OECD, Tax Challenges Arising from the Digitalisation of the Economy – Global Anti-Base Erosion Model Rules (Pillar Two), Side-by-Side Package (OECD 5 Jan. 2026) [hereinafter Side-by-Side Package], at ch. 4, para. 8 and ch. 5, para. 28. The SbS Safe Harbour also requires the UPE jurisdiction to have a qualified regime listed in the Central Record.

[54] OECD, Tax Challenges Arising from the Digitalisation of the Economy – GloBE Information Return (September 2026) (OECD 2026) [hereinafter GIR (Sept. 2026)], at Introduction, para. 36.1 (applies to Fiscal Years beginning on or after 31 Dec. 2025).

[55] GloBE Commentary (2026), at annex A ch. 2 s. 4, box 7.4, paras. 1–2 and paras. 196–197 (jurisdictions must make it available for Fiscal Years beginning on or after 31 Dec. 2026 and may do so from 31 Dec. 2025; for the group it remains an election); Side-by-Side Package, at ch. 2, box 7.4.

[56] GloBE Commentary (2026), at annex A ch. 1, box 1.1, para. 2 (“Transition Period”) and para. 24; Side-by-Side Package, at ch. 3, paras. 3–4.

[57] Art. 11 Pillar Two Directive (2022/2523) (QDMTT optional); GloBE Model Rules, at art. 10.1 (“Transition Year”, defined per jurisdiction).

[58] OECD, Global Minimum Tax: Support for Central GloBE Information Return Filing and Exchange (2024 Reporting Fiscal Year) (first published 18 May 2026, rev. 6 July 2026), paras. 1–4 and nn. 2 and 4.

[59] GloBE Commentary (2026), at annex A ch. 1, box 1.1, para. 2 (“Transition Rate” (a)–(c)); Side-by-Side Package, at ch. 3, para. 3.

[60] GloBE Model Rules, at arts. 9.2.1–9.2.2. The Pillar Two Directive words its table differently: the rates apply to Fiscal Years “beginning from 31 December” of each listed year (art. 48(1)–(2) Pillar Two Directive (2022/2523)). Read literally, a Fiscal Year beginning in 2024 falls in the 2023 row (10% / 8%). National transposition governs; Sweden follows the Model Rules (SE: Lag (2023:875) om tilläggsskatt [Act on Top-up Tax] [hereinafter Lag (2023:875)], transitional provisions, points 4–5).

[61] Side-by-Side Package, at ch. 3, paras. 1–3; GloBE Commentary (2026), at annex A ch. 1, box 1.1, para. 2.

[62] SE: ch. 8, secs. 2–3 Lag (2023:875) om tilläggsskatt [Act on Top-up Tax], as consolidated to SFS 2026:305 (rates up to Fiscal Years beginning in 2026; not for years ending after 30 June 2028); SE: Prop. 2026/27:4 Nya förenklingsregler och andra kompletteringar i lagen om tilläggsskatt [Government Bill: New Safe Harbours and Other Supplements to the Top-up Tax Act] (8 Oct. 2026), sec. 6.1.

[63] GloBE Commentary (2026), at annex A ch. 1, box 1.2, para. 1 (“Qualified CbC Report”, “Qualified Financial Statements”); annex A ch. 1, paras. 2 and 8.

[64] GloBE Commentary (2026), at annex A ch. 1, paras. 3 and 27 (exception for a jurisdiction where the group had no Constituent Entities in the earlier year: para. 28). The rule applies to years in which the group is subject to the GloBE Rules.

[65] GloBE Commentary (2026), at annex A ch. 1, para. 29.

[66] GloBE Model Rules, at arts. 1.1.1–1.1.2; art. 2(2) Pillar Two Directive (2022/2523); GloBE Commentary (2026), at ch. 1, para. 15 (the method of proration may be set locally); contrast OECD, Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 – 2015 Final Report (OECD 2015), annex IV to ch. V, Country-by-Country Reporting Implementation Package, Model Legislation, at art. 1(3) (immediately preceding year).

[67] OECD, Tax Challenges Arising from the Digitalisation of the Economy – Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two), September 2026 (OECD 2026) [hereinafter AG (Sept. 2026)], at ch. 2, paras. 3 and 6–11 (revised para. 3.c and new para. 3.d of box 3.1; new paras. 18.1–18.4; amended para. 21 and new paras. 21.1–21.6 of annex A.3 to the Commentary; new paras. 20.4–20.5 of the Commentary on art. 5.2.3). Special relief applies to a group’s Fiscal Year beginning in 2024 (new para. 21.3).

[68] GloBE Commentary (2026), at ch. 1, paras. 13.2–13.5.

[69] GloBE Commentary (2026), at ch. 1, paras. 13.6–13.8.

[70] GIR (Sept. 2026), at Introduction, para. 36.1 (including the clarifying notes for Reporting Fiscal Years commencing before 31 Dec. 2025).

[71] OECD, GloBE Information Return (Pillar Two) XML Schema, October 2026: User Guide for Tax Administrations (OECD 20 Oct. 2026), Foreword and Introduction (version 1.0 “until 15 June 2028”; version 2.0 “from 25 June 2028 to all exchanges”).

[72] Arts. 8ae(3) and 27d(3)–(4) Council Directive 2011/16/EU of 15 February 2011 on Administrative Cooperation in the Field of Taxation and Repealing Directive 77/799/EEC, OJ L64 (2011) [hereinafter DAC (2011/16)], as inserted by Council Directive (EU) 2025/872 of 14 April 2025 amending Directive 2011/16/EU on Administrative Cooperation in the Field of Taxation, OJ L, 2025/872 (6 May 2025) [hereinafter DAC9 (2025/872)].

[73] GloBE Commentary (2026), at annex A ch. 4, box 4.1, para. 2 and para. 4 (example of a 53-week Fiscal Year from 28 Dec. 2025 to 2 Jan. 2027).

[74] Ch. 8, sec. 14 Lag (2023:875) (“slutar före den 31 december 2026”); SE: Prop. 2026/27:4 Nya förenklingsregler och andra kompletteringar i lagen om tilläggsskatt [Government Bill: New Safe Harbours and Other Supplements to the Top-up Tax Act] (8 Oct. 2026), at p. 16 (proposed new last sentence of ch. 8, sec. 14, second para.: “slutar före den 4 januari 2027”), sec. 6.2 (p. 23) and sec. 13 (pp. 49–50: entry into force 1 Jan. 2027; the reporting entity may elect to apply all or some of the provisions from tax years beginning after 31 Dec. 2024).

[75] GloBE Commentary (2026), at ch. 10, para. 18 (“The Implementation Framework will further consider and provide guidance with respect to Fiscal Years that exceed 12 months …”). Not addressed in AG (Sept. 2026), the GIR XML Schema user guide (Oct. 2026) or other sources reviewed as at 22 Oct. 2026.

[76] GloBE Commentary (2026), at annex A ch. 4, box 4.1, para. 2 (“run no longer than 12 months”).

[77] OECD CbCR: OECD, Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 – 2015 Final Report (OECD 2015) [hereinafter Action 13 Report], at para. 52; Action 13 Report, annex IV to ch. V, Model Legislation, at art. 1(3); OECD, Guidance on the Implementation of Country-by-Country Reporting: BEPS Action 13 (OECD May 2024) [hereinafter CbC Guidance], at ch. 4, sec. 3, Q. 3.2. EU public CbCR: art. 48b(1) Directive 2013/34/EU of the European Parliament and of the Council of 26 June 2013 on the Annual Financial Statements, Consolidated Financial Statements and Related Reports of Certain Types of Undertakings, OJ L182 (2013), as amended by Directive (EU) 2021/2101 of the European Parliament and of the Council of 24 November 2021 amending Directive 2013/34/EU as regards Disclosure of Income Tax Information by Certain Undertakings and Branches, OJ L429 (2021) [hereinafter Accounting Directive (2013/34)]. Pillar Two: OECD, Tax Challenges Arising from the Digitalisation of the Economy – Global Anti-Base Erosion Model Rules (Pillar Two) (OECD 2021) [hereinafter GloBE Model Rules], at arts. 1.1.1–1.1.2.

[78] EU: art. 48d(1)–(2) Accounting Directive (2013/34). Australia: sec. 3D(3) AU: Taxation Administration Act 1953 (Cth) (Compilation No. 226, 27 Aug. 2026) [hereinafter TAA 1953].

[79] Art. 48b(4)–(6) and art. 48d(1) Accounting Directive (2013/34).

[80] OECD, Tax Challenges Arising from the Digitalisation of the Economy – Consolidated Commentary to the Global Anti-Base Erosion Model Rules (2026) (OECD 2026) [hereinafter GloBE Commentary (2026)], at annex A ch. 1, box 1.1, para. 2 (“Transition Rate”); GloBE Model Rules, at arts. 9.2.1–9.2.2; contrast art. 48(1)–(2) Council Directive (EU) 2022/2523 of 14 December 2022 on Ensuring a Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union, OJ L328 (2022) [hereinafter Pillar Two Directive (2022/2523)] (rates keyed to Fiscal Years “beginning from 31 December” of each listed year).

[81] OECD, Tax Challenges Arising from the Digitalisation of the Economy – Global Anti-Base Erosion Model Rules (Pillar Two), Side-by-Side Package (OECD 5 Jan. 2026) [hereinafter Side-by-Side Package], at ch. 3, paras. 1–3; GloBE Commentary (2026), at annex A ch. 5, box 5.1, para. 7.

[82] Action 13 Report, at annex III to ch. V, sec. B (“on a consistent basis”); GloBE Commentary (2026), at ch. 1, paras. 13.2–13.8.

[83] CbC Guidance, at ch. 4, sec. 3, Q. 3.3–3.4; arts. 48a–48h and art. 48c(5), second subpara. Accounting Directive (2013/34); secs. 3D(1)(b), 3D(1)(e) and 3D(2)(a) TAA 1953; GloBE Model Rules, at art. 1.1.2; GloBE Commentary (2026), at ch. 10, para. 18.

[84] GloBE Commentary (2026), at annex A ch. 1, paras. 3, 27 and 29.