Perspectives · Tax
The first public country-by-country reports are due this year
Directive (EU) 2021/2101 requires groups with consolidated revenue above EUR 750 million in each of the last two financial years to publish a report on income tax information, broken down by member state and by each listed non-cooperative jurisdiction. For most calendar-year groups the first report covers the 2025 financial year and must be published by the end of 2026. The timing is not uniform: Romania, Croatia and Sweden applied their rules to earlier financial years, and Hungary, Spain and Slovenia require publication sooner than twelve months after the balance sheet date. Publication venues, language and website obligations also differ by member state. This perspective is general information, not legal advice.
24 August 2026 · Tax
The disclosure
Tax information that anyone can read
Country-by-country data has been reported to tax authorities for years, in confidence, under a separate regime. This directive takes a similar idea and makes it public. The report is filed with a commercial register and, in many member states, published on the group's own website, free of charge and kept available for years afterwards. It uses a common template and a defined electronic format, so it can be read and compared by anyone who wants to.
The content is what a reader would expect and a little more: revenues, employees, profit before tax, tax accrued and tax paid, and accumulated earnings, presented separately for each EU member state and for each jurisdiction on the EU lists of non-cooperative and monitored jurisdictions, with other jurisdictions aggregated. The report also carries a list of the group's subsidiaries and a description of what they do. That list is where a governance team should look first: it is the only part of the report that can be checked against something the group already holds.
The dates
Twelve months, unless a member state shortened it
The directive was to be transposed by member states in 2023 and applied from the first financial year starting on or after 22 June 2024, with publication within twelve months of the balance sheet date. For a group with a calendar year end that makes the 2025 financial year the first in scope and the end of 2026 the date to publish. It is the version of the timetable most groups have been working to.
Member states did not all legislate to it. Romania applied its rules from financial years beginning on or after 1 January 2023 and its first reports were published at the end of 2024, Croatia from financial years beginning on or after 1 January 2024, and Sweden from financial years commencing on or after 1 June 2024. Hungary requires publication four or five months after the year end, Spain six months and Slovenia eleven. A group with entities across the EU therefore has several dates, and the earliest one governs.
The local end
Published in a subsidiary's name, about the whole group
The obligation does not stop at EU-headed groups. A group parented outside the EU is reached through its medium-sized and large EU subsidiaries and its qualifying branches, and the report those entities publish covers the whole group. That is an uncomfortable arrangement for a portfolio company: a local managing director, filing with a local register, publishing figures assembled several time zones away.
It also raises a question about accountability at the local end. The directive contemplates a subsidiary that cannot obtain all the information having to say so in the report it publishes. Whether that arises is a group question, but the consequence lands on a named entity and its directors, and it is answered locally, in the local language, in several member states. A group that discovers the reporting entity and the language requirement in November has left itself very little room.
The report will be read next to the statutory accounts and the structure chart on the group's website, and discrepancies are the sort of thing a limited partner notices. So the control before publication is a reconciliation: does the subsidiary list in the report match the group's own entity register at the year end, and are the jurisdictions right. An entity dissolved during the year, or acquired late in it, is where the two lists usually part company. Settle the naming while there is time, because the legal name in the register, the trading name in the accounts and the name in the tax data are often three strings for one company.
In Alethia
The entity list the report has to agree with
The group's entities are held with their legal names, jurisdictions, ownership and officers, the documents filed against them and compliance obligations with due dates, all under an audit trail. That is the list the published report has to reconcile with, and holding it in one governed place settles the argument about which version was current at the year end.
Because the obligation lands on particular entities in particular member states, it is recorded where it belongs: an obligation against the publishing subsidiary, with its own due date, its own owner, and the published report filed against it as evidence. Alethia does not prepare tax data, produce the report or file it with any register. A year later, when somebody asks what was published in Hungary and who signed it, the answer is attached to the Hungarian entity.
Questions
Scope, timing and the first reports
Is the end of 2026 the deadline for every in-scope group?
No. It is the ordinary position for a calendar-year group whose first in-scope financial year was 2025, publishing within twelve months of the balance sheet date. Several member states applied their rules to earlier years or require publication sooner, so a group present in Hungary, Spain or Slovenia may face a date well before December, and the earliest applicable date is the one to plan for.
Our parent is outside the EU. Are we outside the rules?
Not necessarily. Medium-sized and large EU subsidiaries and qualifying branches of a group above the threshold can be required to publish, and what they publish concerns the group rather than themselves. The practical questions are which entity carries the obligation in each member state, and who provides it with the group figures.
Can we publish the country-by-country report we already give the tax authorities?
Treat it as a separate exercise. The public report has its own scope, its own presentation rules including the separate treatment of listed jurisdictions, and its own electronic format. Where a figure differs from the confidential return, the group should know why before someone else asks.
The subsidiary list is the checkable part
Before publication, match the report's subsidiary list and jurisdictions to the entity register at the year end, and settle which entity publishes in each member state and in which language.