1. Understanding the Danish Public CbCR Framework
The EU Public CbCR rules apply in Denmark to large multinational groups and standalone undertakingsheadquartered in Denmark with consolidated revenue exceeding EUR 750 million for two consecutive years.The rules apply to financial years starting on or after June 22, 2024, and the report must be made publicwithin 12 months after the end of the relevant financial year. For groups with a calendar financial year, thefirst relevant reporting period will therefore be financial year 2025, with the first report due by December 31,2026.
For non-EU-headquartered companies, the rules apply to their qualifying Danish entities, i.e., medium-sizedor large subsidiaries and medium-sized or large branches of non-EU group entities, if the group’sconsolidated revenue exceeds the applicable reporting threshold. However, banks and investment firms thatare subject to CbCR obligations under CRD IV are exempt from this Directive. The Danish implementationbroadly adopts the EU Public CbCR disclosure framework. The disclosure requirements are similar to thoseof the OECD CbCR framework but are more limited in scope. A key distinction is that there is no requirementto separately disclose related-party revenue and third-party revenue. Further information on the EU Public CbCR framework, including the general rules and implementation status across member states, is available on the KPMG EU Tax Centre’s Country-by-Country Reporting page.
What makes Denmark’s implementation different?
Although the EU Public CbCR rules are intended to create a common transparency framework, local implementation differences may affect compliance. For groups with operations in Denmark, three areas deserve particular attention.
a. EEA disaggregation
Along with some other EU member states, Denmark requires data for EEA jurisdictions (Iceland, Norway, and Liechtenstein) to be disaggregated, along with data for EU jurisdictions and jurisdictions deemed non-cooperative by the European Parliament (the “blacklist”), as well as certain jurisdictions with pending commitments (the “gray list”). All other jurisdictions may be reported in an aggregated “rest of the world” line.
b. Multiple reporting exemption
Under Denmark’s implementation of the multiple reporting exemption (MRE), non-EU-headquartered groups may rely on a Public CbCR report filed by another EU group entity and published on the ultimate parent entity’s website. However, that report must comply with the Danish implementation rules, including EEA disaggregation, and must be filed by the qualifying Danish entities in accordance with Danish rules. As a result, the exemption functions as relief from preparing a separate report rather than as a full exemption from local compliance.
c. Website publication and five-year accessibility
Denmark’s implementation also emphasizes public accessibility. While the Public CbC report does not need to be hosted directly on the Danish entity’s website, a link to the report, as made available through the Danish Public Register, must be hosted on the website and remain accessible for five years.
2. Technical filing requirements
A further practical consideration in Denmark’s implementation is the filing format accepted by the Danish Business Authority (Erhvervsstyrelsen).
The Danish Business Authority began accepting Public CbCR filings in May 2026 through Regnskab Speciel and requires reports to be submitted in XHTML/iXBRL format; reports in PDF format will not be accepted. However, an accompanying explanatory document in PDF format may also be uploaded.
3. How Nordic companies are approaching Public CbCR
Experience across the Nordic region indicates that companies are responding to Public CbCR requirements in different ways. The approach often depends on the group’s existing tax transparency profile, reporting footprint, stakeholder expectations, and whether the group is also subject to other public reporting regimes, such as Australia’s Public CbCR rules.
In practice, three different approaches are emerging.
Some groups are taking a minimum compliance approach, focusing on preparing and submitting the required reports in the relevant jurisdictions without developing a separate tax transparency report. For these companies, the main priority is to meet the legal requirements and prepare for potential questions once the information becomes publicly available.
Other groups are choosing to accompany the mandatory data with a narrative. This may include explanations of the group’s tax policy, business model, and approach to tax governance. Such context can be particularly relevant where CbC data may not, on its own, provide a complete picture of the group’s activities or value creation. A smaller group of companies is using Public CbCR as part of a total tax transparency agenda. These companies often go well beyond the minimum disclosure requirements by providing additional context on their tax strategy, taxes paid and collected, and wider economic and societal contribution. Across these approaches, companies are considering a number of common questions: how to coordinate EUand Australian Public CbCR requirements; how Public CbCR interacts with Pillar 2 and sustainabilityreporting; when the report should be published; and whether additional internal review or assuranceprocedures are appropriate.
For groups with Danish operations, these broader considerations should be assessed alongside the Danish-specific requirements. EEA disaggregation, Danish filing obligations, website publication, and XHTML/iXBRLreadiness may all influence how the group structures its Public CbCR process.
4. Final observations
Denmark’s implementation of the EU Public CbCR Directive illustrates how local legislation can influence thepractical operation of a reporting framework that was intended to be broadly harmonized across Europe.While the core reporting requirements are based on the EU framework, Danish-specific elements, includingEEA disaggregation, the practical operation of the multiple reporting exemption, website publicationobligations, and technical filing requirements, will require additional planning, particularly for non-EU-headquartered groups.
Public CbCR should not be viewed solely as a compliance requirement. Businesses should recognize that theinformation disclosed will be publicly available and accessible to a wide range of stakeholders. As a result,Public CbCR presents not only a compliance challenge but also an opportunity to proactively communicatethe group’s tax profile and contribution to the economies in which it operates.
At KPMG Acor Tax, we support both Danish and non-EU-headquartered groups with their Public CbCRobligations, from understanding and assessing reporting requirements and designing a reporting strategy topreparing compliant EU Public CbC reports in the mandated format and supporting submissions to the DanishBusiness Authority.
We help organizations align Public CbCR with their wider tax reporting landscape, including OECD CbCR,Pillar 2, and other transparency initiatives, such as Australia’s Public CbCR regime.
Beyond compliance, we assist companies in developing and implementing tax transparency strategies. Thisincludes helping businesses communicate their tax profile, tax governance, and economic contributionthrough tax transparency reports, public tax policies, and total tax contribution reporting.
If you would like to discuss your Public CbCR obligations or tax transparency strategy, please reach out to us.
