Over the past decade, country-by-country reporting (CbCR) has become a foundational element of international tax compliance. Introduced under the OECD’s base erosion and profit shifting (BEPS) project, CbCR requires multinational enterprise groups (MNE Groups) with total consolidated revenues above € 750 million to report annually on income, taxes paid, and economic activity in each jurisdiction in which they operate. While these reports were originally designed for confidential exchange between tax authorities, the global push for greater corporate transparency is now transforming the reporting landscape.
EU public country-by-country reporting (pCbCR): Requirements and scope
In 2021, the European Union (EU) adopted a landmark regulation requiring public country-by-country reporting (pCbCR) – a significant step toward making corporate tax data accessible not just to governments, but also to the public. Under this regime, large MNEs must disclose financial and operational information in all EU Member States and other European Economic Area (EEA) members, as well as jurisdictions on the EU’s tax blacklist and, in some cases, the greylist.
Although pCbCR requires less detail than traditional CbCR, the implications for compliance systems are far-reaching. Companies must decide what to disclose, what to omit, and how to justify those omissions. Crucially, even if sensitive information is withheld from the public report, the company must still collect and assess it internally.
This is where tax technology becomes indispensable.
Tax technology for public CbCR: Streamline compliance
Advanced tax tech solutions – spanning automated data extraction, validation workflows, audit trails, and reporting platforms – enable MNE Groups to meet evolving regulatory demands with accuracy, speed, and scalability. Tools that can integrate CbCR and pCbCR processes streamline compliance and reduce the risk of inconsistencies between private tax filings and public disclosures. Moreover, strong tax data governance is essential for managing transparency obligations while protecting commercially sensitive information.
Australia has since followed the EU's lead, introducing legislation requiring public country-by-country disclosures for qualifying multinationals. As more jurisdictions adopt public reporting standards, the pressure on MNE Groups to upgrade their tax compliance infrastructure will only increase.
Implications for in-house tax teams: Preparing for transparency
For in-house tax professionals, this signals a paradigm shift. Public CbCR is not just a policy development – it is a technological challenge. Those who embrace modern tax tech tools will not only ensure compliance but also gain a strategic advantage in navigating the complexities of global tax transparency.
