EU Public Country-by-Country
Reporting (CbCR): a new transparency
requirement

Tax transparency remains a key focus within European regulation. With the introduction of EU Directive 2021/2101 in December 2021, a new obligation has been created: EU Public Country-by-Country Reporting (Public CbCR).

This directive requires large multinational enterprises to publicly disclose information about their activities, profits and corporate income tax paid per country. The aim is to provide insight into where profits are generated and where tax is paid, both within and outside the EU.

The rules apply no later than for financial years starting on or after 22 June 2024. For most Dutch organisations with a calendar year, this means:

• first reporting year: 2025
• first publication deadline: no later than 31 December 2026

Who does this obligation apply to?

The EU Public CbCR obligation applies to enterprises that:

• have consolidated revenue of more than € 750 million in each of the last two financial years; and
• are established in the EU, or
• are established outside the EU but have at least one qualifying medium-sized or large EU subsidiary or a comparable EU branch.

Standalone undertakings established in an EU Member State that also exceed the € 750 million revenue threshold fall within the scope as well.

Please note! banks and certain investment firms are excluded.

The thresholds to determine whether a subsidiary or branch qualifies are as follows:

• Subsidiaries must meet at least two of the following three criteria:
  • € 5 million balance sheet total
  • € 10 million net turnover
  • an average of fifty employees
• Branches only need to meet the net turnover threshold in each of the last two financial years.

Member States may apply higher thresholds within the limits of the directive. You therefore need to assess the criteria on a country-by-country basis.

In the Netherlands, the directive has been implemented through the Implementation Decree of 14 February 2024. The Dutch thresholds for medium-sized and large entities are:

• € 7.5 million balance sheet total
• € 15 million net turnover
• an average of fifty employees

Please note! that other countries, including Belgium, Spain and the United Kingdom, apply different thresholds and criteria. Through the international Moore Global network, our tax specialists work closely with accountancy and advisory firms across borders to support internationally operating businesses with these requirements.

Who is responsible for the report?

For groups with an EU head office, the ultimate parent company must prepare and publish the report in its Member State.

For groups headquartered outside the EU, the parent company may publish the report on its own website. One EU subsidiary or branch must file the report with the national trade register. It is essential to determine in good time which entity is responsible and to align your internal processes accordingly.

What must the CbC report include?

For each country, you must publicly disclose at least the following information:

• a brief description of activities
• number of employees (FTE)
• revenue, including related-party transactions
• profit or loss before tax
• corporate income tax accrued for the current year
• corporate income tax paid
• retained earnings

The report must:

• present information separately for each EU Member State
• separately disclose information for countries on the EU list of non-cooperative jurisdictions or the “grey list” if included for two consecutive years
• present information for all other countries on an aggregated basis

Publication requirements and reporting format

The report must:

• be made publicly available free of charge, for example via the trade register and your website
• be prepared in a standardised XHTML format using Inline XBRL (iXBRL)
• remain publicly accessible for at least five years

Unlike some other EU countries, the Netherlands does not provide an exemption from website publication.

There is, however, a temporary option to defer the disclosure of sensitive information if publication could cause serious commercial harm.

Practical impact for Dutch organisations

Although much of the required data is already available through existing OECD CbCR reports, public reporting brings additional considerations:

• increased visibility for stakeholders such as the media, NGOs and the general public
• reputational risks in the case of unusual tax positions
• the need for consistent communication and aligned data
• technical requirements, including iXBRL tagging

How Moore DRV can support you

Moore DRV is a member of Moore Global, a worldwide network of accountancy and advisory firms. This gives you access to extensive knowledge, experience and local expertise across the globe. Where needed, we can quickly connect you with the right specialists, wherever your business operates.

Given the data collection, technical preparation (iXBRL), internal validation and international coordination required, we strongly recommend starting your preparations well before the December 2026 deadline.

At Moore DRV, our international tax specialists ensure that your Dutch and any EU activities fully comply with the EU Public Country-by-Country Reporting directive.

Our services include:

• assessing whether your organisation falls within the scope of EU Public CbCR
• identifying the responsible reporting entity
• analysing Dutch and international legislation
• preparing or reviewing the report
• aligning Public CbCR with other reporting obligations
• iXBRL tagging and compliance with publication requirements