Extending the definition of a Significant Global Entity (SGE) - November 2019

4 days left to have your say
Consultation Type
Draft Legislation

Key Documents

The Government announced in the 2018-19 Budget that it was extending the definition of a Significant Global Entity (SGE) beyond groups headed by listed companies and by private companies required to prepare general purpose financial statements.

SGE is a concept to define, generally speaking, a group of entities, interrelated by a control relationship that could enable non-arm’s length dealings and therefore be of special interest to tax authorities.

Originally devised to determine application of OECD Country-by-Country reporting requirements, the SGE definition is now also used to determine application of the Multinational Anti-Avoidance Law, the Diverted Profits Tax and penalties applying to false or misleading statements, late lodgement or tax schemes. Also SGEs are required to prepare general purpose financial statements where a non-SGE may only be required to prepare special purpose financial statements.

By extending the definition to include members of large business groups headed by private companies, trusts, partnerships, investment entities and individuals, the draft legislation will ensure the multinational tax avoidance rules apply to all relevant entities, and that Australia can meet its OECD Country-by-Country reporting commitments.

Consultation on an earlier draft of this measure took place between July and August 2018. Subsequently, some technical changes have been made to the draft legislation and it is again being released for consultation.


You can submit responses to this consultation up until 11 December 2019. Interested parties are invited to comment on this consultation.

While submissions may be lodged electronically or by post, electronic lodgement is preferred. For accessibility reasons, please submit responses sent via email in a Word or RTF format. An additional PDF version may also be submitted.

All information (including name and address details) contained in submissions will be made available to the public on the Treasury website unless you indicate that you would like all or part of your submission to remain in confidence. Automatically generated confidentiality statements in emails do not suffice for this purpose. Respondents who would like part of their submission to remain in confidence should provide this information marked as such in a separate attachment.

Legal requirements, such as those imposed by the Freedom of Information Act 1982, may affect the confidentiality of your submission.

View our submission guidelines for further information.

How To Respond




Address written submissions to:

The Manager
Corporate and International Tax Division
Langton Cres
Parkes ACT 2600


Email: corporate.tax@treasury.gov.au
Phone: Brian McKay +61 2 6263 2035