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EU: Updated public country-by-country reporting forms published

Implementing regulation effective for financial years starting on or after January 1, 2025

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November 19, 2024

The European Commission (EC) on October 21, 2024, published an updated implementing regulation providing the common template and electronic reporting formats for the application of the EU public country-by-country (CbC) reporting directive. A public consultation on the draft template and reporting forms was held until September 6, 2024 (read KPMG E-News).

The updated regulation—including the annex laying down the reporting form—is largely in line with the ones subject to the public consultation and only minor amendments were made. The updated documents clarify that:  

  • In-scope groups are allowed to disclose additional information in the CbC report, in the form of text, images or other means.
  • “Section  3 – List of subsidiaries and activities” will only include the list of subsidiaries. Establishments, fixed places of business or permanent business activities other than those operating via a subsidiary undertaking need not be disclosed.
  • “Section 5 (non-mandatory) – Explanations for material discrepancies between income tax paid and accrued” only applies when required by the applicable national law. In all other cases it is left to the discretion of reporting undertakings whether or not to provide such information.

Additionally, non-mandatory elements under the directive—such as assets, capital, the split between related and third-party revenues, or subsidies, which were originally included in "Table 2 - List of taxonomy elements"—have now been moved to a new table titled "Table 3 - List of additional taxonomy elements." This change suggests that these data points are considered optional and only need to be disclosed by in-scope groups if they choose to do so voluntarily.

The updated regulation received a favorable opinion on October 18, 2024, from the Accounting Directive Committee, which was a necessary step before the EC could adopt it. Once adopted by the Commission, the regulation will come into force on the twentieth day after its publication in the Official Journal of the EU. The regulation will apply to CbC reports prepared for financial years starting on or after January 1, 2025.

For more information on public CbC reporting, see KPMG’s dedicated webpage.

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