Overview of public CbC reporting obligations in Spain
The EU public country-by-country (CbC) reporting directive was implemented in Spain through Law 28/2022 of December 21, 2022, effective for financial years beginning on or after June 22, 2024. For companies with a financial year coinciding with the calendar year, the first report will thus be for financial year 2025. Under the Spanish public CbC law, the report must be approved and published within six months (versus 12 months under the EU directive) of the end of the financial year. Thus, the first report must be published in June 2026 for companies with a financial year coinciding with the calendar year.
The European Commission (EC) on December 2, 2024, published in the EU Official Journal the common template and electronic reporting formats for public CbC reports prepared for financial years starting on or after January 1, 2025. CbC reporting has been mandatory in Spain since 2016 using form 231, and while very similar in terms of content, there are differences between the information that must be disclosed on form 231 versus on the newly approved EU public CbC report.
Read a February 2025 report prepared by the KPMG member firm in Spain that includes a table illustrating the differences in the information to be included in each report.