Recently, a number of large multinational enterprises (“MNEs”) have been subject to increased public scrutiny on the amount of tax they are paying in different countries. This trend is set to continue with the first wave of public country-by-country (“CbC”) reports being published over coming months.
It is important that in-scope MNEs are prepared for any publicity these reports could generate and the Matheson tax team has been assisting a number of MNE clients in this regard.
Recent press coverage
Recent updates to US accounting standards have resulted in MNEs publishing data on the amount of tax paid in different countries for the first time. This has triggered a number of articles in the press comparing the amount of tax paid in different countries, showing how quickly media attention can intensify around corporate tax policies of MNEs.
Increased transparency has resulted in journalists, policymakers, investors and the wider public having direct access to corporate tax information that may be misinterpreted without proper context. Often times crude figures reported for regulatory purposes don’t tell the whole story especially when such information is viewed and interpreted in isolation but can make for easy headlines in the press.
These additional disclosures in the US are due to be followed shortly by the publication of CbC reports in Australia and across the EU.
EU Public CbC Reporting
As flagged in previous Matheson publications, large MNEs with substantial operations in the EU are now required for the first time to publicly disclose key financial and tax information on a jurisdictional basis pursuant to a recent EU Directive.[1]
Large MNEs with annual consolidated revenues exceeding €750 million for the previous two consecutive financial years are in scope and must publicly disclose financial data on a jurisdictional basis by way of a public CbC report. These requirements apply to both EU-based MNEs and non-EU based MNEs with significant EU operations.
The public CbC report must include financial data for the whole group which must be provided on a country-by-country basis for each EU Member State and each country on the EU ‘blacklist’[2] or ‘greylist’[3]. Information can then be aggregated for the rest of the world.
These rules came into effect for financial years beginning on or after 22 June 2024 and the relevant information must be published within 12 months of the financial year end. Therefore, MNEs with a 31 December financial year-end must publish information related to FY25 by 31 December 2026.
The public CbC report must disclose details of net turnover, profit or loss before tax and employee headcount. The European Commission have made a public CbC report generator available to MNEs in order to facilitate preparation of the report and also published the following template of the information to be disclosed:
| Tax jurisdiction | Country code | Revenues | Profit (loss) before income tax | Income tax paid – on cash basis | Income tax accrued – current year | Accumulated earnings | Number of employees |
| 1. Full name of Member State or tax jurisdiction A | |||||||
| 2. Full name of Member State or tax jurisdiction B | |||||||
| 3. … | |||||||
| All other tax jurisdictions (aggregated basis) |
It is possible to defer publication of certain information for five years if the publication of this information would be seriously prejudicial to the commercial position of the entity or its ultimate parent entity and there is limited guidance as to how this test should be interpreted.
Filing in Ireland
Ireland has implemented the EU public CbC reporting rule in the European Union (Disclosure of Income Tax Information by Certain Undertakings and Branches) Regulations 2023.
Where an MNE makes its filing in Ireland, the CbC report must be made available on the group’s website for a minimum period of five years or be published on the website of the Companies Registration Office (“CRO”). Public CbC reports submitted to the CRO will be made available on the CRO’s Document Library, which launched on 14 January 2026 and, as of the date of publication of this article, only one filing is currently publicly available.
Preparation is key
To effectively navigate this new transparency environment, it will be important for MNEs to understand the details that will be included in any CbC reports and how that information might be interpreted. This will allow groups to prepare for any unwarranted public scrutiny and ensure alignment with the business and public relations teams to ensure that these disclosures are compliant with the necessary filing requirements and accompanied by additional information to explain the group’s global tax strategy.
With the financial year for the first public CbC reporting obligations already underway for most in-scope groups it is essential that MNEs prepare now for this additional layer of public filing obligations. The Matheson team has been assisting clients in advance of their first filing dates and are available to discuss any queries you may have.
Contact us
For more information, please contact any member of our Tax team or your usual Matheson contact.
[1]. Directive (EU) 2021/2101.
[2]. As of the date of writing this article, Annex I of the Council conclusions on the revised list of non-cooperative jurisdictions for tax purposes includes the following jurisdictions: American Samoa; Anguilla; Guam; Palau; Panama; Russian Federation; Turks and Caicos Islands; US Virgin Islands; Vanuatu; and Viet Nam.
[3]. As of the date of writing this article, Annex II of the Council conclusions on the revised list of non-cooperative jurisdictions for tax purposes includes the following jurisdictions: Belize; Brunei Darussalam; Eswatini; Greenland; Jordan; Türkiye; Montenegro; and Türkiye.