EU: “Public” country-by-country reporting directive published in EU Official Journal

Directive will enter into force on 21 December 2021.

Directive will enter into force on 21 December 2021.

Text of Directive (EU) 2021/2101 (of 24 November 2021) introducing “public” country-by-country (CbC) reporting for certain undertakings and branches was published today, 1 December 2021, in the Official Journal of the EU.

  • The Directive will enter into force on the twentieth day following the date of its publication—i.e., the entry into force will be on 21 December 2021.
  • EU Member States then have until 22 June 2023 to transpose the Directive into domestic legislation.
  • The rules will apply, at the latest, from the commencement date of the first financial year starting on or after 22 June 2024.
  • The deadline for publishing the report on income tax information (as provided for under the Directive) is 12 months of the balance sheet date of the financial year for which the report is drawn up. For calendar year taxpayers, the first reporting year will be financial year 2025, and the report will be due by the end of December 2026.

Read the release in the Official Journal

Overview of public CbC reporting

The new rules require multinational groups with a total consolidated revenue of €750 million to report either if they are EU parented or otherwise have EU subsidiaries or branches of a certain size. The report will require information on all members of the group (including non-EU members) within seven key areas:

  • A brief description of activities
  • Number of employees
  • Net turnover (including related-party turnover)
  • Profit or loss before tax
  • Tax accrued
  • Tax paid
  • The amount of accumulated earnings

The information must be broken down for each EU Member State where the group is active and also for each jurisdiction deemed “non-cooperative” by the EU or that has been on the EU’s “grey” list for a minimum of two years. Information concerning all other jurisdictions may be reported on an aggregated level.  

Reports are to be published in an EU Member State business register, but also on the companies’ websites, where the CbC reports are to remain accessible for at least five years. When the ultimate parent is not governed by the law of an EU Member State, the reporting will generally have to be done by the EU subsidiaries or branches, unless the ultimate parent publishes a report including those subsidiaries and branches.  

Additional information about the EU’s public CbC reporting rules is available on a dedicated KPMG webpage.

For more information, contact a KPMG tax professional:

Raluca Enache |

Robert Van der Jagt |

John DerOhanesian |

Federica Porcari |


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