CbC reporting penalties are not set by the OECD. BEPS Action 13 created the obligation to file a Country-by-Country report once a multinational group crosses the consolidated revenue threshold, but it left the sanction for missing that obligation entirely to domestic law. There is no single “CbC fine” — there are over 100 separate penalty regimes, most of them thin, outdated, or barely documented in English. What follows is a verified comparison, built only from primary legal text and tax authority guidance, not from the secondary blog posts that most “CbC penalty” roundups quietly copy from each other. Where a figure could not be confirmed against an official source, it has been left out rather than approximated — a judgment call explained at the end.

What Actually Triggers a CbC Reporting Penalty?

Three distinct failures carry separate exposure in most jurisdictions that have transposed BEPS Action 13: not filing the CbC report at all, filing it late, and filing it with inaccurate or incomplete data. A fourth, less discussed trigger matters more at scale: failing to file where required forces the obligation down to every constituent entity in that jurisdiction individually — the “secondary mechanism” or local filing requirement built into the OECD Model Legislation and most domestic transpositions (including the EU’s DAC4 and the US Treasury regulations). That fourth trigger is usually where the real cost sits, not the headline fine.

CbC Reporting Penalties by Country: 2026 Comparison Table

The table below covers the jurisdictions for which exact figures could be verified directly against statute, tax authority guidance, or the EU directive text itself.

Canada, Singapore, Switzerland, Japan, France and Spain all impose CbC filing penalties too. Canada and Switzerland were checked directly against primary legal text for this article — the Income Tax Act’s general information-return penalty table (CRA) and the Swiss Federal Tax Administration’s CbCR guidance respectively — but neither source set out a CbC-specific figure distinct from the general regime, so nothing is quoted rather than reproducing an approximate number from a secondary summary. Singapore, Japan, France and Spain are omitted for the same reason: no figure found this cycle that could be pinned to the primary statute or the tax authority’s own text rather than a law-firm alert. That gap will close incrementally as future updates check the remaining primary sources directly.

The Australian Outlier, and What It Signals

Australia is not a rounding error on this table — it is a different design philosophy. Most jurisdictions set CbC penalties at the level of an ordinary filing-failure fine, which is why the UK, US and German figures above sit in the hundreds to low tens of thousands. Australia’s Significant Global Entity regime does the opposite on purpose: it takes the standard failure-to-lodge base penalty and multiplies it by 500, specifically because the ordinary penalty was judged too small to change behaviour for a multinational group large enough to be an SGE. That is a regulator stating outright what this article argues generally: a flat, modest fine is a cost of doing business at this revenue scale, not a deterrent — and one jurisdiction has already rebuilt its penalty around that fact rather than ignoring it.

The US Exception: When the Penalty Itself Got Litigated

The clearest sign that CbC-adjacent penalty regimes are less settled than they look is Farhy v. Commissioner. In 2023 the US Tax Court held that the IRS had no statutory authority to directly assess — as opposed to pursue through a civil lawsuit — penalties under §6038(b), the same provision that backs Form 8975. The DC Circuit Court of Appeals reversed that decision in May 2024, restoring the IRS’s assessment authority. For two years, in practice, a cornerstone penalty of the US international information-reporting regime was not reliably enforceable through the IRS’s normal collection process. A compliance function that read the fine print on the Tax Court’s 2023 ruling and treated the exposure as settled would have been wrong twice in eighteen months. The lesson generalizes: a penalty figure printed in a statute and a penalty that is actually collectible are not the same fact, and that gap is routinely invisible in CbC compliance checklists.

Why the Real Risk Still Isn’t the Fine — Even in Australia

Outside Australia’s deliberately punitive regime, every verified figure above is small relative to the compliance infrastructure a group this size already runs. £300, $10,000, €10,000 — none of it moves a budget for a group clearing the €750 million CbC threshold (see our 2026 threshold comparison by jurisdiction). And even where the fine itself is large, as in Australia, it is still not the whole exposure. Three other mechanisms matter more across the board:

The secondary filing mechanism. When the ultimate parent fails to file — whether through penalty-tolerant indifference or a genuine systems failure — the obligation does not disappear. It cascades to every constituent entity resident in a jurisdiction with a local filing rule, each potentially facing its own notification and filing burden instead of one consolidated report. The multi-entity compliance cost of that cascade dwarfs any fixed penalty.

Safe harbour and audit-selection exposure. CbC data increasingly feeds directly into transfer pricing risk assessment and, under Pillar Two, into whether a group can rely on the transitional CbCR safe harbour at all (see our breakdown of what currently qualifies). A late or visibly inaccurate CbC report is a flag a tax authority’s risk-assessment algorithm does not need a fine to notice.

Exchange relationship suspension. Under the OECD’s CbC Multilateral Competent Authority Agreement and the EU’s DAC4 exchange network, a jurisdiction can be suspended as an exchange partner for systemic non-compliance, which forces every group with a presence there back onto local filing across the board — a structural cost with no fixed penalty attached at all, and no straightforward way to reverse it quickly.

None of that shows up in a penalty comparison table. It is the reason a compliance team should treat the fines above as a floor on seriousness, not a ceiling on consequence.

FAQ: CbC Reporting Penalties

What is the penalty for not filing a CbC report?

It depends entirely on where the filing entity is resident, and the range is wide. Confirmed 2026 figures run from £300 plus £60 per day in the UK and up to €10,000 in Germany, through $10,000 plus up to $50,000 in continuation penalties in the US, to AUD 182,000 rising to AUD 910,000 in Australia for a significant global entity. There is no OECD-wide figure — see the comparison table above for sourcing.

Can the same CbC report trigger penalties in more than one country?

Yes. If the ultimate parent’s jurisdiction fails to file, or its exchange relationship with a given country lapses, the secondary/local filing mechanism can require constituent entities in multiple jurisdictions to file independently — each exposed to that jurisdiction’s own penalty regime.

Does the OECD set the penalty amount for CbC non-compliance?

No. BEPS Action 13 and the OECD’s Model Legislation recommend that jurisdictions apply penalties consistent with their existing domestic filing-failure regimes, but the amount, structure and enforcement mechanism are set entirely by each country’s own law. Australia is the clearest example of a jurisdiction choosing not to follow that convention.

Is a low CbC penalty a sign that non-compliance is low-risk?

No, even where the fine is genuinely small. The larger exposure comes from secondary filing obligations, loss of Pillar Two safe harbour eligibility, and increased audit selection risk — none of which carry a fixed-dollar cap.

Sources checked directly for this article: HM Revenue & Customs factsheet CC/FS59, Country-by-Country Reporting Penalties; the US IRS Form 8975 instructions and the IRS international information reporting penalties page; the German Bundeszentralamt für Steuern’s CbCR FAQ; the Australian Taxation Office’s significant global entity penalties guidance; and the Hong Kong Inland Revenue Department’s penalty policy. This is general information on published penalty regimes, not tax advice for any specific group’s filing position.