EU Public CbC Reporting Rules

On December 21, 2023, the Belgium’s Chamber of Representatives adopted the draft law transposing the EU directive on public Country-by-Country (“CbC”) Reporting. The draft law is still subject to final publication / promulgation, and is generally aligned with the text of the EU Directive.

The EU Public CbC Reporting Rules will require multinational groups operating in the EU (whether headquartered within or outside of the EU) that exceed certain size thresholds to publish certain information on their tax affairs. In general, the same consolidated turnover threshold of EUR 750 million applicable to the Action 13 CbC reporting requirements apply to the Public CbC Reporting requirements.  The rules will apply from the commencement date of the first financial year starting on or after June 22, 2024.  For Groups with financial years coinciding with the calendar year, the first year of reporting in Belgium will apply to FYE December 31, 2025.  Publication / filing with the Belgian National Bank is due 12 months after the financial year end.  Failure to comply with the disclosure requirement will result in administrative fines between EUR 50 and EUR 10.000, with potential further consequences in the event of fraudulent intent.

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