Public Country-by-Country Reporting: when tax data meets public scrutiny

It requires large multinational enterprises (MNEs) to publicly disclose tax and financial information on a country-by-country basis, marking a shift from confidential reporting to greater public accountability.

The main objective of Public CbCR is to enhance transparency and increase trust in the tax system. It addresses concerns around profit shifting and whether MNEs pay taxes where economic value is created. By making tax data accessible, stakeholders including investors, regulators and the public can better assess corporate tax behaviour.

Who does public country-by-country reporting apply to?

The regulations are applicable to entities regulated by Irish law if they are:

• The ultimate parent entity of a large MNE, or a standalone entity, with consolidated revenues exceeding €750 million for the last two consecutive financial years.
• A large or medium sized subsidiary of a non-EU based ultimate parent entity where the consolidated revenue of the group exceeds the €750 million threshold.
• A branch in Ireland of a non-EU MNE with a net turnover above €12 million for the last two consecutive financial years.

What is reported?

Entities within scope must publicly disclose detailed tax and financial information for each EU Member State and for jurisdictions on the EU list of non-cooperative countries, with aggregated data for other jurisdictions. The required disclosures typically include:

• Name of the ultimate parent / standalone entity and Country of registered office.
• Financial year (start and end) and reporting currency.
• Details of net turnover, other operating income and income from any other investments; profit or loss before tax, income tax accrued and paid in cash, accumulated earnings (retained profits) and number of employees.
• A list of all subsidiaries in the consolidated group which are based in the EU or in an EU blacklisted] or grey listed country.
• Description regarding nature of activities carried out.

This information enables users to understand where profits are generated and how taxes are paid globally.

When does this apply?

The Irish rules apply to financial years beginning on or after 22 June 2024. The report must be made publicly available within 12 months of the balance sheet date, either on the company’s website or through the Companies Registration Office (CRO). It must be accessible to the public free of charge and remain available for a minimum period of five years from the publication date. In Ireland, the report is typically required to be published in an official language of the State (English or Irish), ensuring broad accessibility and transparency for stakeholders. For companies with 31 December as the year end date, the first reports are expected to be published by 31 December 2026.

Are there exemptions?

Certain exemptions apply under the Irish Public CbCR framework. For example:

• Companies operating solely within one EU Member State and not in any other jurisdictions may be exempt.
• The MNE group with an Irish subsidiary that is not a medium-sized or large undertaking.

The Regulations specify for a five-year deferral from reporting for information which may “seriously prejudice the undertaking’s competitive position”.

Are there penalties?

While the EU Directive requires Member States to enforce compliance, the specific penalties are determined at a national level. In Ireland, companies must ensure timely and accurate publication of reports; failure to comply may result in regulatory consequences such as fines or enforcement actions that may result in imprisonment. Beyond formal penalties, there is also a significant reputational risk. As the data is publicly accessible, inconsistencies or perceived aggressive tax positions could attract scrutiny from stakeholders, media and regulators.

Where required information is not available, subsidiaries or branches must request it from the parent and may need to publish a statement indicating non-availability if the parent does not provide it.

What should you do now?

Organisations within scope should begin assessing their readiness for Public CbCR. This includes identifying in-scope entities, evaluating data availability and consistency with existing financial and tax disclosures, and establishing robust internal processes and controls for data collection and validation. Given the public nature of the disclosures, companies should also consider the broader narrative and potential stakeholder interpretation of the reported information, aligning tax reporting with overall ESG and communication strategies. Early preparation will be key to ensuring compliance while managing reputational risk effectively.

At Forvis Mazars Ireland, we support clients through each stage of this process from scoping and data readiness assessments to designing reporting frameworks and assisting you navigate compliance requirements with confidence.