Public country-by-country reporting (CbCR) is going live: is your tax story ready?

For multinational groups operating in the Netherlands, public country-by-country reporting (CbCR) applies to financial years beginning on or after 22 June 2024, and calendar-year groups will generally publish their first report for 2025 by 31 December 2026. A group is ready when it can explain what investors, tax authorities, journalists, NGOs and competitors will conclude from the report. The deadline matters, but the public interpretation matters more. Readiness gives multinational groups time to test the data, protect legitimate commercial interests and turn a mandatory disclosure into credible evidence of governance and responsible tax conduct. Filing the report with the Dutch Trade Register and publishing it on the company’s website are statutory obligations.

This article was written by Juan Dosal (jdosal@rsmnl.nl) and Livia Bare (lbare@rsmnl.nl) of RSM Netherlands. Juan and Livia are tax consultants with RSM Netherlands with a focus on ESG and supply chain management.  

What does public CbCR change, and why does readiness create an advantage?

Public CbCR moves information that was historically exchanged confidentially between multinational enterprises and tax authorities into the public domain. Revenue, profit, corporate income tax, accumulated earnings, employees and business activities can be compared by jurisdiction, copied into databases and assessed against annual reports, sustainability claims and peer disclosures. That shift creates a clear advantage for groups that prepare early.

They can understand the picture before publication, correct data weaknesses, explain legitimate differences, and decide how their tax governance and economic contribution should be presented. Groups that wait until the deadline risk publishing a technically complete table without being able to influence how it is interpreted.

Public CbCR data will not be read in isolation. Readers can compare profit with employees, tax paid with profit before tax, current tax with accumulated earnings, and the public report with statutory accounts, the private CbCR, [LINK: Pillar Two, RSM Pillar Two service page] information and ESG reporting. Automated databases are already making those comparisons easier. Without preparation and context, normal business circumstances may look unusual. Loss carry forwards can depress cash tax, and a timing difference can separate tax accrued from tax paid.

Acquisitions and supply chain restructurings can move profit and employees between jurisdictions. Holding, financing, sales and manufacturing activities may be aggregated into one country line. These outcomes may all be legitimate, but unexplained figures leave room for others to define the narrative.  

The practical risks include:

• reputational challenge from investors, journalists, NGOs or employees;
• questions from tax authorities where public information appears inconsistent with private filings;
• competitor analysis of margins, cost structures or market performance;
• investor or lender concern about tax controversy, governance and future cash-tax exposure;
• inconsistency with sustainability or responsible-business statements;
• a late or incomplete filing that becomes visible through the statutory audit report; and
• board-level accountability for a disclosure process that was treated as a tax-team exercise.

Public CbCR is connected to statutory financial reporting. Where the financial statements of a Dutch entity are subject to statutory audit, the auditor must state in the audit report whether, for the financial year preceding the year under audit, the entity was required to publish a public CbCR and, if so, whether it was published in accordance with the applicable requirements. This is not an audit opinion on the accuracy or tax merits of the public CbCR. It is, however, a visible compliance statement in the statutory audit report. Failure to prepare or publish on time can therefore become part of the company’s external financial-reporting record, rather than remaining an internal tax-compliance matter. The auditor’s involvement means a group needs clear ownership, evidence of filing, controls over website publication and a governance process it can repeat every year.

Which groups must publish a public country-by-country report, and what must it contain?

The regime generally applies to multinational groups with consolidated revenue exceeding €750 million in each of two consecutive financial years and a qualifying EU presence. Depending on the structure, the obligation may sit with an EU ultimate parent, an EU standalone undertaking, or a qualifying EU subsidiary or branch of a non-EU group. The report generally presents, for each EU and EEA jurisdiction and each relevant EU-listed jurisdiction, items such as revenues, profit or loss before corporate income tax, corporate income tax accrued and paid, accumulated earnings, average number of employees, a brief description of activities and the relevant subsidiaries included in the consolidated financial statements. Other jurisdictions may generally be presented on an aggregated basis. Filing in another country does not automatically remove every Dutch requirement. The group must verify the publishing entity, legal conditions, format, language, Trade Register filing and website accessibility.

How can a mandatory table become evidence of a well-governed business?

Some multinationals already publish more than the mandatory public CbCR and present tax transparency as evidence of responsible management rather than as a defensive compliance exercise. Their public tax package combines country-by-country information with a tax contribution report, a board-approved tax policy, an explanation of the business and investment cycle, tax-risk governance, cooperative-compliance information and independent recognition. Not every group needs to copy that package in full, but the data become more credible when readers can see the governance, controls and economic reality behind them.

A well-prepared public CbCR can help a group:

• build investor confidence by showing how tax outcomes relate to genuine economic activity;
• tell its own story before third parties interpret isolated figures;
• demonstrate effective tax governance and a functioning Tax Control Framework;
• support ESG, procurement and responsible-business credentials;
• improve consistency in engagement with tax authorities, lenders and investors;
• strengthen internal data ownership across tax, finance, supply chain management and the wider business; and
• prepare for future tax transparency and assurance requirements.

These benefits are not automatic. An unexplained report, an aggressive narrative or a weakly supported omission can increase scrutiny, so the commercial value lies in accuracy, consistency and credible context.

Public CbCR is mandatory for in-scope groups. The quality of the preparation and the strength of the story remain within the company’s control. Our advice is to start early, which gives the group time to understand the published picture, resolve inconsistencies, protect legitimate commercial interests and demonstrate responsible tax governance. Waiting until the filing deadline leaves those judgments to others, at the moment the data become public, and the auditor must report on whether publication occurred. The best-prepared groups will publish on time, with information that is accurate, explainable and aligned with the business they want readers to understand.

RSM is a thought leader in the field of supply chain management including international tax. We provide frequent insights through training and thought leadership, based on detailed knowledge of industry developments and practical application gained from working with our clients. RSM helps companies connect individual geopolitical and regulatory developments to the broader changes affecting their supply chains. By doing so, we support businesses in distinguishing short-term disruption from structural change and translating that assessment into coordinated decisions on sourcing, origin, landed cost, logistics and supply-chain design. If you would like to discuss what these connected developments mean for your business, please contact one of our consultants.