{"id":"F2024L01713","name":"Taxation Administration (Country by Country Reporting Jurisdictions) Determination 2024","slug":"taxation-administration-country-by-country-reporting-jurisdictions-determination-2024","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":442691,"registerId":"F2024L01713-fast-fetch-1775957643432","compilationNumber":null,"startDate":"2026-04-12","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"1","sectionType":"section","heading":"Taxation Administration (Country by Country Reporting Jurisdictions) Determination 2024","content":"---\nmeta-content-style-type: text/css\nmeta-content-type: application/xhtml+xml; charset=utf-8\n---\n\n![Commonwealth coat of arms of Australia](image.001.jpeg)\n\n \n\nTaxation Administration (Country by Country Reporting Jurisdictions) Determination 2024\n\nI, Andrew Leigh, Assistant Minister for Competition, Charities and Treasury, make the following determination.\n\nDated   12 December 2024\n\n \n\nDr Andrew Leigh\n\nAssistant Minister for Competition, Charities and Treasury  Parliamentary Secretary to the Treasurer\n\n \n\n \n\n \n\n \n\nContents\n\nPart 1—Preliminary\n\n1  Name \n\n2  Commencement\n\n3  Authority\n\n4  Definitions\n\nPart 2—Determination of country by country reporting jurisdictions\n\n5  Country by country reporting jurisdictions\n\n \n\nPart 1—Preliminary\n\n \n\n1  Name\n\n  This instrument is the Taxation Administration (Country by Country Reporting Jurisdictions) Determination 2024.\n\n2  Commencement\n\n (1) Each provision of this instrument specified in column 1 of the table commences, or is taken to have commenced, in accordance with column 2 of the table. Any other statement in column 2 has effect according to its terms.\n\n \n\n- Commencement information\n- Column 1 Column 2 Column 3\n- Provisions Commencement Date/Details\n- 1. The whole of this instrument The later of:\n\n1. the day after this instrument is registered; and\n2. the day Schedule 4 to the Treasury Laws Amendment (Responsible Buy Now Pay Later and Other Measures) Act 2024 commences.However, the provisions do not commence at all if the event mentioned in paragraph (b) does not occur.\n\n\nNote: This table relates only to the provisions of this instrument as originally made. It will not be amended to deal with any later amendments of this instrument.\n\n (2) Any information in column 3 of the table is not part of this instrument. Information may be inserted in this column, or information in it may be edited, in any published version of this instrument.\n\n3  Authority\n\n  This instrument is made under the Taxation Administration Act 1953.\n\n4  Definitions\n\n  In this instrument:\n\nthe Act means the Taxation Administration Act 1953.\n\nPart 2—Determination of country by country reporting jurisdictions\n\n5  Country by country reporting jurisdictions\n\nUnder subsection 3DA(4) of the Act, a jurisdiction specified in an item of the following table is specified as a jurisdiction for the purposes of subparagraph 3DA(1)(d)(ii) of the Act in respect of the reporting periods specified in the relevant item of the table:\n\n \n\n- Country by country reporting jurisdictions\n- Item Specified jurisdiction Reporting periods\n- Jurisdictions that have a comprehensive international tax agreement with Australia\n- 5 Singapore All periods starting on or after 1 July 2024\n- 10 Switzerland All periods starting on or after 1 July 2024\n- Other jurisdictions\n- 20 Andorra All periods starting on or after 1 July 2024\n- 25 Anguilla All periods starting on or after 1 July 2024\n- 30 Antigua and Barbuda All periods starting on or after 1 July 2024\n- 35 Aruba All periods starting on or after 1 July 2024\n- 40 Barbados All periods starting on or after 1 July 2024\n- 45 Bahamas All periods starting on or after 1 July 2024\n- 50 Bahrain All periods starting on or after 1 July 2024\n- 55 Belize All periods starting on or after 1 July 2024\n- 60 Bermuda All periods starting on or after 1 July 2024\n- 65 British Virgin Islands All periods starting on or after 1 July 2024\n- 70 Cayman Islands All periods starting on or after 1 July 2024\n- 75 Cook Islands All periods starting on or after 1 July 2024\n- 80 Curacao All periods starting on or after 1 July 2024\n- 85 Dominica All periods starting on or after 1 July 2024\n- 90 Gibraltar All periods starting on or after 1 July 2024\n- 95 Grenada All periods starting on or after 1 July 2024\n- 100 Guernsey All periods starting on or after 1 July 2024\n- 105 Hong Kong All periods starting on or after 1 July 2024\n- 110 Isle of Man All periods starting on or after 1 July 2024\n- 115 Jersey All periods starting on or after 1 July 2024\n- 120 Liberia All periods starting on or after 1 July 2024\n- 125 Mauritius All periods starting on or after 1 July 2024\n- 130 Monaco All periods starting on or after 1 July 2024\n- 135 Montserrat All periods starting on or after 1 July 2024\n- 140 Nauru All periods starting on or after 1 July 2024\n- 145 Niue All periods starting on or after 1 July 2024\n- 150 Panama All periods starting on or after 1 July 2024\n- 155 Republic of the Marshall Islands All periods starting on or after 1 July 2024\n- 160 Saint Kitts and Nevis All periods starting on or after 1 July 2024\n- 165 Saint Lucia All periods starting on or after 1 July 2024\n- 170 Saint Maarten (Dutch Part) All periods starting on or after 1 July 2024\n- 175 Saint Vincent & the Grenadines All periods starting on or after 1 July 2024\n- 180 Samoa All periods starting on or after 1 July 2024\n- 185 San Marino All periods starting on or after 1 July 2024\n- 190 Seychelles All periods starting on or after 1 July 2024\n- 195 Turks and Caicos Islands All periods starting on or after 1 July 2024\n- 200 US Virgin Islands All periods starting on or after 1 July 2024\n- 210 Vanuatu All periods starting on or after 1 July 2024\n\n\n \n","sortOrder":0}],"analysis":{"flash_summary":{"complexity_score":3,"scope_assessment":{"changed":false,"description":"The instrument mechanically specifies jurisdictions for the operation of existing s 3DA(1)(d)(ii) of the Act. It does not amend the Act or alter the statutory criteria; it simply lists jurisdictions and reporting periods. The text gives no indication that this alters the original statutory scope beyond identification of jurisdictions."},"complexity_factors":["Legal cross-reference to the Taxation Administration Act 1953 (subsection 3DA(4)) — requires users to read both instruments.","Commencement is conditional on another Act’s Schedule (Commencement table, s 2), creating timing uncertainty.","Long prescribed list of jurisdictions (s 5) requires taxpayers to check whether specific operating countries are included.","Minimal administrative discretion in the instrument itself — it is a literal list, not principles-based.","Practical compliance impact on multinational groups: expands/clarifies the set of jurisdictions that trigger reporting obligations from 1 July 2024.","Potential interaction with other international tax reporting rules (requires taxpayers to reconcile multiple instruments)."],"plain_english_summary":"This determination names the foreign jurisdictions that count as ‘country-by-country reporting jurisdictions’ under the Taxation Administration Act 1953 (see subsection 3DA(4) and s 5). It affects multinational groups and Australian entities required to lodge country-by-country reports by clarifying which foreign locations trigger those reporting rules for periods starting on or after 1 July 2024. The Assistant Minister made the list; commencement is conditional on a separate Act’s Schedule (see s 2), so timing and compliance planning matter for affected taxpayers."},"flash_summary_failed":{"failed":true,"reason":"Unauthenticated. Configure AI_GATEWAY_API_KEY or use a provider module. Learn more: https://ai-sdk.dev/unauthenticated-ai-gateway","source":"analysis-cron"},"kimi_summary":{"content_quality":"ok","complexity_score":2,"scope_assessment":{"changed":false,"description":"The instrument performs exactly the function its title suggests: determining which jurisdictions qualify for country by country reporting. The list of 38 jurisdictions (tax havens plus Singapore and Switzerland) aligns precisely with the original policy intent of the OECD's Base Erosion and Profit Shifting (BEPS) Action 13 framework, which Australia adopted. No scope creep is evident."},"complexity_factors":["Only 5 operative provisions (sections 1-5), with section 5 being the only substantive content","Single defined term ('the Act') in the interpretation section","No nested conditional logic or cross-references beyond basic statutory hooks (subsection 3DA(4) and subparagraph 3DA(1)(d)(ii))","Straightforward tabular format listing 38 jurisdictions with identical reporting period triggers","Commencement provision contains a simple conditional (later of two dates, with fail-safe if event doesn't occur), but this is standard legislative boilerplate","No exceptions, exemptions, or penalty provisions within the instrument itself"],"plain_english_summary":"This instrument publishes an official list of 38 \"country by country reporting\" jurisdictions, designated by the Assistant Minister for Australian tax purposes and effective 1 July 2024. It specifically names Singapore and Switzerland plus 36 commonly used tax-haven jurisdictions.\n\nIt affects large multinational groups headquartered in Australia (global revenue above €750m) and the ATO’s review work: those multinationals must report detailed profits, taxes, employees and assets for operations in these places, making profit-shifting into those jurisdictions harder."}},"importantCases":[],"_links":{"self":"/api/acts/taxation-administration-country-by-country-reporting-jurisdictions-determination-2024","history":"/api/acts/taxation-administration-country-by-country-reporting-jurisdictions-determination-2024/history","analysis":"/api/acts/taxation-administration-country-by-country-reporting-jurisdictions-determination-2024/analysis","conflicts":"/api/acts/taxation-administration-country-by-country-reporting-jurisdictions-determination-2024/conflicts","importantCases":"/api/acts/taxation-administration-country-by-country-reporting-jurisdictions-determination-2024/important-cases","documents":"/api/acts/taxation-administration-country-by-country-reporting-jurisdictions-determination-2024/documents"}}