The Australian Taxation Office (ATO, the land-down-under version of the Internal Revenue Service) this week released the first data drop from its newly required country-by-country tax reports. The data promise to provide an important new window into how the biggest, most profitable U.S. corporations are booking their income in low-tax jurisdictions around the world—a window that U.S. disclosures often leave firmly closed.
For example, the new disclosures show that the Apple corporation booked fully a quarter of its worldwide profits in Singapore last year, despite generating only 3 percent of its revenues there using 2 percent of its employees. This disclosure adds welcome color to the monochrome picture of its foreign activities that Apple shared with its shareholders in last week’s annual financial report, which discloses only that Apple reduced its worldwide income taxes by $2.7 billion through its activities in Singapore. Apple doesn’t even disclose a Singapore presence in the terse list of 20 subsidiaries it told its shareholders about last week. Apple executives were slightly more effusive in its subsidiary disclosure to Australian authorities, disclosing a total of 255 distinct subsidiaries. (The Australian disclosures don’t include the location of the subs, so we can’t know how many of these were required to generate Apple’s enormous Singapore profits.)
The credit card giant Visa reports a similarly implausible Singapore result, allegedly “earning” 62 percent of its worldwide profits in Singapore with 13 percent of its revenues and just 7 percent of its employees. Visa’s Singapore staff apparently delivered a superhuman 73 percent profit margin on its sales last year, compared to a 7 percent profit margin for the rest of the world. The company’s 6 percent Singaporean tax rate may have something to do with Visa’s eagerness to pretend its profits are being meaningfully earned there.
For companies that claim to be utterly unprofitable in the U.S., the new Australian data tells us plenty about why that’s happening. The medical device maker Becton Dickinson, which told shareholders it lost money in the U.S. despite making $1.8 billion in the rest of the world last year, discloses making $266.2 million of pretax income in the Cayman Islands last year. This was done with revenues of $266.3 million. The company’s absurd 99.96% profit margin in the Caymans is made easier by the fact that the company discloses having precisely zero employees there.
What makes this especially interesting is that Becton shareholders perusing the company’s most recent annual financial report— in which the company is supposed to fully explain its activities to shareholders and the public—would look in vain for any reference to the company’s lucrative Caymans “activities.” In fact, the only island referenced even once in the company’s 10-K is Rhode.
Becton also tells Australian authorities it has 355 subsidiaries around the world. In this respect, at least, Becton is (mostly) coming clean to its shareholders as well. In an addendum to its 2025 10-K, Becton informed shareholders that it had 345 subsidiaries around the world, of which three were based in the Caymans.
It is, at least in relative terms, a golden age for corporate tax disclosure. The new Australian requirements are a helpful complement to the almost-as-new disclosures emerging since this summer from the European Union, which in turn add details to the expanded disclosures companies are now required to make to U.S. shareholders due to new requirements from the criminally underappreciated Financial Accounting Standards Board.
But the lurid details in this first tranche of Aussie data show clearly that some of the biggest and most profitable American companies are choosing to keep their shareholders in the dark about their offshore activities at precisely the moment when Congress needs to know more about how to fix the gaping holes in our corporate tax laws.
Fortunately, a legislative fix already exists: the Disclosure of Tax Havens and Offshoring Act, introduced this summer by Sen. Chris Van Hollen and Rep. Brittany Pettersen. The incoming Democratic majority’s quest for greater accountability to the American public surely won’t begin with country-by-country reporting, but the first tranche of Australian disclosures is a clear reminder that this makes it far more difficult for big corporations to get away with hiding their U.S. profits abroad. This will be an important step in rebuilding the public’s trust in our institutions generally, and our tax system.
