Public Country-by-Country Reporting (CbCR) is an EU-led initiative designed to increase tax transparency by requiring multinational enterprise (MNE) groups to publicly disclose key financial and tax-related information on a country-by-country basis.
Who Does It Apply To?
Under EU Directive 2021/2101, the public CbCR rules generally apply to MNE groups with consolidated global revenues exceeding €750 million for each of the last two consecutive financial years. The rules cover:
- EU-headquartered groups
- Non-EU headquartered groups with a significant EU presence, defined as having medium or large subsidiaries or branches in the EU. These are typically entities that meet at least two of the following criteria:
- Total assets over €5 million
- Net turnover over €10 million
- More than 50 employees
Australia has also introduced similar requirements for reporting periods commencing on or after 1 July 2024, with reports due within 12 months of the period end. For example, for a group with a reporting period from 1 January to 31 December, the first in‑scope period started on 1 January 2025, and the 2025 report must be published publicly by 31 December 2026.
Implementation Timeline
Most EU countries will begin applying these rules for financial years starting on or after 22 June 2024. So the first reports will need to be published under the EU rules in June 2026, for June year ends. Though similar to Australia, for calendar year-end companies, the first reports will be due by 31 December 2026.
However, some countries have introduced earlier publication deadlines:
- Hungary: Reports generally due within 6 months of the year‑end (4 months for Hungarian entities whose securities are traded on a regulated market in any EEA country), with a possible extension to 12 months for non‑EU‑headquartered groups
- Spain: Reports due within 6 months of the financial year‑end
Other countries have accelerated timelines:
- Romania: First reporting year is 2023, with reports having been due by 31 December 2024
- Croatia: First reporting year is 2024, with reports due by 31 December 2025
- Sweden: Effective for financial years beginning after 31 May 2024
Local rules must be carefully monitored to ensure compliance.
What Needs to Be Reported?
Information to be disclosed would include:
- Name of the ultimate parent
- Nature of activities
- Number of employees
- Revenues
- Profit/loss before tax
- Taxes accrued and paid
- Accumulated earnings
Penalties for non-compliance
The Public CbCR directive mandates that member states apply fines for non-compliance (non-submission or omissions), provided that these penalties are “effective, proportionate and dissuasive”.
“Although the majority of EU member states will begin applying the public CbCR rules from 2026, covering accounting periods ending on or after June 2025, multinational groups should remain vigilant. Several countries, such as Romania and Croatia, have adopted accelerated timelines, which could catch some businesses off guard. Additionally, many multinationals may have concerns about the public disclosure of sensitive country-by-country data. There is a risk that such information could be over-analysed or misinterpreted by stakeholders, customers and suppliers. Hence, proactive communication and contextual explanation will be key to managing reputational risk.”
Chris Danes, International Tax Partner, MHA
