Internationally active organisations are increasingly expected to be transparent about their tax position. With the introduction of EU Directive 2021/2101, a new obligation has been established: EU Public Country-by-Country Reporting (Public CbCR).
This directive is particularly relevant for large multinational groups with consolidated revenues exceeding € 750 million. Dutch organisations with international activities may also be affected, for example when they are part of an international group or have a qualifying EU subsidiary or branch.
In this article, we explain what EU Public CbCR entails, when the rules apply, what information must be disclosed, and how you can prepare in time. Want to learn more? Explore our frequently asked questions on CbCR.
The rules apply to financial years starting on or after 22 June 2024. For most Dutch organisations with a calendar financial year, this means that 2025 will be the first reporting year.
The first publication must be completed by 31 December 2026. It is therefore important to start preparing early, allowing sufficient time for data collection, internal alignment and technical reporting.
EU Public CbCR applies to organisations with consolidated revenues exceeding €750 million in the last two financial years.
The requirement may apply to:
Please note: banks and certain investment firms are excluded.
To determine whether an EU subsidiary must report, size criteria apply. A subsidiary qualifies if it meets at least two of the following:
For branches, only the net revenue threshold applies, assessed over the last two financial years.
Different thresholds may apply per country, so a country-by-country assessment is essential.
In the Netherlands, EU Public CbCR has been implemented via legislation dated 14 February 2024. For Dutch subsidiaries, the thresholds for medium-sized and large entities apply:
Keep in mind that other countries may apply different criteria.
Responsibility depends on the structure of your group.
Identifying the responsible entity early is key to organising your processes and responsibilities effectively.
The report must include, for each country, information such as:
The data must be:
The report must:
In the Netherlands, publication on the website is mandatory.
In specific cases, publication of sensitive information may be postponed if disclosure would cause significant commercial harm.
Although much of the required data is already available through OECD CbCR reporting, public disclosure introduces additional challenges:
Moore MKW is part of Moore Global, a worldwide network of accounting and advisory firms. This enables us to combine local expertise in the Netherlands with international knowledge.
Our international tax specialists support you with interpreting the rules, preparing or reviewing the report and handling technical aspects such as iXBRL tagging. We also consider the interaction with other reporting obligations and your international structure.
We support internationally active organisations with:
Given the complexity of data collection, technical requirements and international coordination, we recommend starting preparations well before the December 2026 deadline.
Would you like to understand whether your organisation is in scope or how to prepare effectively? Get in touch with us. We are happy to think along with you and support your specific situation.
Want to know more?
EU Public CbCR stands for EU Public Country-by-Country Reporting. This requirement obliges large multinational organisations to publicly disclose information about their activities, profits and corporate income tax paid in each country where they operate.
This provides greater insight into where organisations create value worldwide and where they pay taxes. The aim is to increase transparency around the tax position of internationally active businesses.
EU Public CbCR applies to large organisations with consolidated revenues exceeding € 750 million in the last two financial years.
The obligation may apply to:
The rules apply to financial years starting on or after 22 June 2024. For most Dutch organisations, this means that 2025 will be the first reporting year.
The first report must be published by 31 December 2026 at the latest. Given the time required for data collection, internal alignment and technical reporting, it is advisable to start preparing well in advance.
Large multinational organisations are required to disclose key information on a country-by-country basis in the CbC report. This includes a brief description of activities, the number of employees, revenue, and profit or loss before tax.
In addition, the report must show the amount of corporate income tax accrued, the amount of tax actually paid, and retained earnings. This provides a clearer picture of the tax position per country.
