For a broader introduction to the reporting requirement and its public-information dimension, please refer to our previous article.
For organisations within scope, this is more than another tax compliance filing. Public CbCR requires reliable data, clear internal ownership and a well-founded explanation of the group’s tax profile that can withstand external interpretation. Figures that are technically accurate may still create reputational risk if they are published without appropriate context.
Who may be in scope?
Public CbCR generally applies to multinational enterprise groups and standalone undertakings where consolidated revenue exceeded EUR 750 million in each of the two preceding consecutive financial years. While the rules primarily affect EU-parented groups, non-EU headquartered groups may also become subject to publication requirements where they operate through qualifying EU subsidiaries or branches.
For many calendar-year groups, the first Public CbCR report will relate tothe 2025 financial year, with publication required within 12 months after the financial year-end. As a result, many companies will be required to publish this information before 31 December 2026.
What becomes public?
The report must disclose selected financial and tax information, including revenue, profit or loss before tax, income tax paid, income tax accrued, number of employees and accumulated earnings. The information must be presented separately for each EU Member State and certain listed jurisdictions, with aggregated reporting for all other jurisdictions under a “Rest of the world” category.
Groups must also disclose a brief description of their activities and relevant group entities. In the Netherlands, publication takes place through filing with the Dutch Trade Register and publication on the company’s website. The report must then remain publicly available for a minimum period.
Our four-phase Public CbCR readiness approach
We help organisations move from uncertainty to a controlled publication process. Our approach combines technical tax analysis, reporting readiness, publication support and stakeholder communication. Depending on an organisation’s level of maturity and specific requirements, our support can range from a focused scope assessment to a comprehensive Public CbCR readiness programme, including a supporting tax transparency narrative.
Phase 1: Scope and responsibility assessment
We begin by determining whether the group falls within scope, which EU entities or branches may trigger a publication obligation, and where responsibility for filing should be assigned. This is particularly relevant for non-EU headquartered groups, where the obligation may arise through EU subsidiaries or branches rather than at the level of the ultimate parent entity.
Our assessment covers the revenue threshold, European presence, branch and subsidiary criteria, timing of the first mandatory publication and the allocation of responsibilities across the group. A key element of this phase is identifying the most appropriate filing hub: the jurisdiction and entity through which the publication obligation can be managed in a controlled, efficient and defensible manner. We also assess whether local implementation differences or Dutch filing requirements create additional practical considerations.
The outcome is a concise scope and responsibility assessment, including a recommended filing-hub position and a practical management action plan. This helps your organisation gain early clarity on whether it is within scope, who must act, which decisions are required and how the publication process should be initiated before reporting deadlines approach.
Phase 2: Data and disclosure readiness
Many organisations already prepare OECD CbCR data that is shared with tax authorities, but Public CbCR is a different exercise. The public report has different presentation requirements, a different audience and a different risk profile. As a result, data must be complete, reconcilable and capable of being clearly explained.
We support clients in mapping existing CbCR, consolidation and tax reporting data to the Public CbCR requirements, validating key figures and identifying gaps or inconsistencies. Particular attention is given to metrics that may attract external scrutiny, such as low effective tax rates, losses in high-revenue jurisdictions, cash tax movements and differences between tax accrued and tax paid.
Where relevant, we also assess whether a safeguard clause may be available for commercially sensitive information and assist in preparing the supporting analysis required to justify its application. This should be considered carefully, as reliance on the safeguard itself may attract additional stakeholder attention.
At the end of this phase, clients have a validated reporting dataset, identified disclosure sensitivities and draft explanatory narratives that prepare the organisation for both technical compliance and stakeholder questions.
Phase 3: Publication execution
We support the execution process from final review through to publication. This includes coordinating internal sign-off, aligning with statutory reporting timelines and supporting XHTML and iXBRL preparation and validation where applicable. We also help integrate Public CbCR into the broader annual compliance calendar alongside tax, finance, legal, ESG and communications workstreams.
The objective is to deliver a timely, compliant and well-controlled publication process while reducing pressure on internal teams and avoiding last-minute issues relating to data, format or governance approvals.
Phase 4: Tax transparency communication
Publication is often the start of stakeholder scrutiny rather than the end of the compliance process.
Once tax information becomes public, stakeholders may ask why profits, employees and taxes paid differ across jurisdictions. Without context, technically accurate data may be interpreted as a tax risk, reputational concern or governance weakness. A clear narrative helps explain the group’s business model, tax governance and contribution in the jurisdictions in which it operates.
Public CbCR often requires collaboration between tax, finance, legal, ESG, investor relations and corporate communications functions.
For clients seeking a focused solution, we assist with the preparation of explanatory notes and stakeholder messaging around key tax and financial metrics. For organisations with broader transparency ambitions, we support the development of a tax transparency report that connects Public CbCR with wider tax governance, ESG reporting, CSRD-related disclosures, Pillar Two messaging and the organisation’s broader sustainability agenda.
Although Public CbCR and Pillar Two serve different purposes, stakeholders may increasingly compare information published under both frameworks. Organisations should therefore assess whether Public CbCR disclosures are consistent with broader tax transparency messaging, including Pillar Two communications, tax governance disclosures and sustainability reporting.
Public CbCR is more than a compliance exercise
Public CbCR represents a significant shift in how multinational groups communicate tax information. Organisations that start preparing early can do more than meet a filing obligation. They can improve data quality, strengthen governance, manage reputational exposure and communicate a credible and consistent tax transparency narrative. The key is to treat Public CbCR as a cross-functional readiness exercise rather than a last-minute compliance task.
Would you like to understand what Public CbCR means for your organisation? Our team would be pleased to help assess whether you are within scope, identify the most appropriate filing approach and prepare a clear roadmap towards compliant and well-controlled publication. Please contact our Public CbCR team to discuss how we can support your organisation.
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