SwissHoldings represents the interests of 62 Swiss-based multinational enterprises from the manufacturing and service sectors (excluding the financial sector) such as Nestlé, Roche, Novartis, ABB, Kuehne+Nagel, Schindler and Holcim. We very much welcome the opportunity to provide comments to this Exposure Draft. Our response has been prepared in conjunction with our member companies.
We note that the proposal as currently drafted essentially requires any large global group with Australian operations or an Australian presence to report certain confidential global data on a jurisdiction-by-jurisdiction basis and to have this publicly published, i.e., world-wide on an annual basis, irrespective of where the group is based and hence would capture our member companies.
Importantly and relevantly the proposal goes further than the existing non-public country-by-country (CbC) reporting pursuant to Action 13 of the Organisation for Economic Co-operation and Development’s (OECD’s) base erosion and profit shifting project or that required by the European Union (EU) in its Directive 2021/2101. That is, the proposal (as currently drafted) creates an un-harmonized, separate public reporting regime on top of these existing measures leading to:
- material uncertainty and additional annual (i.e., ongoing) complexity and compliance costs and
- a requirement to publish commercially confidential and sensitive information about the global operations of our member companies with far reaching, complex and difficult (if not impossible) impacts to assess let alone quantify.
We are deeply concerned about this measure and kindly ask to clarify how an Australian regime could obligate such public disclosure of non-Australian information of foreign groups including that of our member companies.
Read the full statement here.