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Multinational tax integrity: Public Beneficial Ownership Register

Author: The Tax Institute

Published Date: 21 Dec 2022


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The Tax Institute welcomes the opportunity to make a submission to the Treasury in relation to the consultation paper on Multinational tax integrity: Public Beneficial Ownership Register (the Consultation Paper).

In the development of this submission, we have closely consulted with our National Large Business and International Technical Committee, National Small and Medium Enterprises Technical Committee, and National Not-for-profit Technical Committee to prepare a considered response that represents the views of the broader membership of The Tax Institute.

The Tax Institute has several concerns with the proposed policy and implementation of a beneficial ownership register (BO register) as outlined in the Consultation Paper. In particular, our members have expressed apprehension at the proposal to require public disclosure of personal information in this way. Disclosure to, and use by, authorised government agencies may assist in the stated objectives in the Consultation Paper. However, we consider that the public disclosure of this personal information significantly increases the likelihood of it being abused and could potentially result in individuals being the target of identity theft, fraud, financial and personal crimes. In our view, and the recent views expressed by the European Court of Justice (ECJ), the risks to individuals and infringement of their rights of privacy and protection of information outweighs any perceived benefits of public disclosure.

Further, the practical application of the proposal is far broader than the stated policy intent of ’ensuring multinational enterprises (MNEs) pay a fairer share of tax’. In practice, the proposal is likely to impact small businesses, privately owned groups and not-for-profit organisations (NFPs). It is unclear how this achieves the stated objective of increasing MNE tax transparency. The Tax Institute is of the view that the proposal should not apply to NFPs and only apply to private groups once a central, government operated register has been established.


  • Published By:The Tax Institute
  • Published On:21 Dec 2022

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