Quick Answer: Public CbCR (EU Public Country-by-Country Reporting)
Public CbCR in the EU is a requirement for large groups to publish a “report on income tax information” with selected tax and business KPIs by jurisdiction under Directive (EU) 2021/2101 (Accounting Directive Articles 48a–48h). If consolidated revenue exceeds €750m in each of the last two consecutive financial years, EU-headed groups (and certain non‑EU groups with qualifying EU subsidiaries/branches) may be in scope (Accounting Directive Art. 48b). The report must be published within 12 months after the balance sheet date (Accounting Directive Art. 48d(1)). The EU-level “latest” commencement date is financial years starting on/after 22 June 2024 (Accounting Directive Art. 48g), which means FY 2025 is the first in-scope year for many calendar‑year groups. From FYs starting on/after 1 Jan 2025, Implementing Regulation (EU) 2024/2952 applies and sets the common template plus XHTML + iXBRL mark-up requirements.
Key Takeaways
- →EU Public CbCR is public corporate reporting—distinct from confidential tax authority CbCR under OECD BEPS Action 13/DAC4.
- →Scope is driven by a €750m revenue threshold (two-year test) and can pull in non‑EU groups through EU subsidiaries/branches.
- →EU Member States must be shown separately; most non‑EU jurisdictions can be aggregated unless on the EU ‘non-cooperative’ list logic.
- →Digital filing (XHTML + iXBRL) becomes the operational bottleneck for many first-time reporters starting with FY2025.
NoteTiming caveat: the Accounting Directive sets an “at the latest” commencement date (financial years starting on/after 22 June 2024). Some Member States chose earlier application dates in national law. If you have entities in early-adopter jurisdictions, confirm the local first-year rule before you assume FY2025 is your first public report.
What EU Public CbCR is (and how it differs from “tax authority CbCR”)
EU Public CbCR is not a transfer pricing filing in the classic sense—it is public corporate disclosure designed to put selected income-tax information into the public domain.
Legal basis and terminology
The core requirement is introduced by Directive (EU) 2021/2101, which amends the Accounting Directive (Directive 2013/34/EU) by adding Chapter 10a (Articles 48a–48h). The deliverable is formally a “report on income tax information” (Accounting Directive Art. 48c).
NoteIf you need a refresher on the confidential regime: “tax authority CbCR” is the OECD BEPS Action 13 template, implemented in the EU through DAC4 (Directive 2011/16/EU as amended; see Annex III reporting instructions). Public CbCR is a separate reporting stream with different fields and public distribution.
Pillar Two note: OECD Pillar Two (GloBE) is a separate regime with separate calculations and filing mechanics; this guide focuses only on EU Public CbCR.
Public CbCR vs OECD/DAC4 CbCR (practitioner differences that matter)
Stakeholders (investors, media, works councils, NGOs) often compare Public CbCR outputs to a group’s tax narrative, financial statements, and—where leaked—confidential CbCR. You should assume comparability questions will arise even when the rules differ.
| Topic | EU Public CbCR (Directive 2021/2101 / Accounting Directive Chapter 10a) | OECD/DAC4 “tax authority CbCR” (BEPS Action 13 / DAC Annex III) |
|---|
| Audience | Public | Tax authorities only (confidential exchange) |
| Threshold (headline) | €750m revenue, two-year test (Accounting Directive Art. 48b) | €750m revenue (Action 13 standard) |
| Jurisdictional split | Separate for each EU Member State; separate for certain listed non‑EU jurisdictions; aggregate “rest of world” (Accounting Directive Art. 48c) | Separate by every tax jurisdiction in the template |
| Key fields | Revenues, PBT, current tax accrued, cash tax paid, employees, accumulated earnings, activities (Accounting Directive Art. 48c(2)) | Revenues (related/unrelated), profit, taxes paid/accrued, capital, retained earnings, employees, tangible assets, etc. |
| Filing mechanics | Published via register + website, kept available 5 years (Accounting Directive Art. 48d) | Filed with tax authority; exchanged via competent authority network |
| Digital format (EU-wide) | Common template + electronic reporting format (XHTML + iXBRL) for reports for FYs starting on/after 1 Jan 2025 (Implementing Regulation (EU) 2024/2952) | XML per local tax authority schemas (varies) |
Why Public CbCR is a transfer pricing and tax controversy issue
Public CbCR data is frequently interpreted as a proxy for “where profit is booked vs where tax is paid,” even though the required fields reflect accounting and cash tax mechanics, not transfer pricing policy per se.
Common “optics triggers” include:
- Low current tax accrued in a profitable jurisdiction (incentives, tax holidays, prior-year true-ups, permanent differences)
- Cash tax paid ≠ current tax accrued (audit settlements, withholding taxes, timing differences)
- Loss-making jurisdictions with headcount and revenues (business cycle, impairment, restructuring)
- High accumulated earnings in specific jurisdictions (historic profitability, dividend policy, local statutory accounts)
WarningTreat EU Public CbCR as a controlled public disclosure, not a “data dump.” Once published, it will be screen‑scraped, compared year‑on‑year, and used to build external “effective tax rate” narratives that ignore timing differences and consolidation effects.
Who must comply with EU Public CbCR (scope and thresholds)
The scope rules are in Accounting Directive Art. 48b and hinge on (i) size, and (ii) whether the group is EU-headed or non‑EU-headed with qualifying EU presence.
The €750m revenue test (two consecutive years)
As a general rule, an undertaking is in scope when consolidated revenue (or revenue for a standalone undertaking) exceeds €750,000,000 for each of the last two consecutive financial years, and the report is prepared for the latter of those two years (Accounting Directive Art. 48b(1)).
EU-headed groups and EU standalone undertakings
An EU ultimate parent undertaking (UPE) (or an EU standalone undertaking) meeting the threshold must publish the report (Accounting Directive Art. 48b).
Key exemption: where the group operates only within one Member State and no other tax jurisdiction, Member States must provide that the obligation does not apply (Accounting Directive Art. 48b(2)).
Banking/CRD “already reporting” exclusion: Member States must also provide that the rule in Art. 48b(1) does not apply where the undertaking (or its affiliated undertakings) already discloses a report under CRD (Directive 2013/36/EU) Article 89 that covers all activities (and, for an EU UPE, all group activities included in consolidated financial statements) (Accounting Directive Art. 48b(3)). This is a meaningful carve-out for many credit institutions.
Non‑EU-headed groups: “pull‑in” via EU subsidiaries and branches
A non‑EU group that meets the €750m threshold can still be pulled into EU Public CbCR through:
- Medium-sized or large EU subsidiaries (as defined under the Accounting Directive size regime as transposed), and/or
- Certain EU branches meeting Member State turnover thresholds (Directive 2021/2101 amending framework; implemented through national law)
Accounting Directive Art. 48b provides the architecture, but the practical trigger points (especially for branches and “medium/large” status) can vary because they rely on national transposition and the Accounting Directive’s size definitions (including updates under Delegated Directive (EU) 2023/2775).
TipNon‑EU groups should maintain a single “EU Public CbCR scope register” listing: EU subsidiaries’ size category by Member State, branch turnover where applicable, and whether the parent intends to use the proxy publication route. This prevents surprises when a single EU entity becomes “large” after a reorg or threshold update.
Proxy publication relief (non‑EU parent publishes once)
To avoid multiple EU subsidiaries/branches publishing overlapping reports, a non‑EU parent can prepare a compliant report and have one designated EU entity publish it—subject to conditions (Accounting Directive Art. 48b and Art. 48d mechanics). The report must be publicly accessible free of charge, in a machine-readable format, and in at least one EU official language within 12 months.
If an in-scope EU subsidiary/branch cannot obtain all required information from the non‑EU parent, it may need to publish:
- the information it has/obtains, and
- a statement that the UPE did not make the necessary information available (Accounting Directive Art. 48b(4)–(5)).
This is a compliance outcome you want to avoid because it creates inconsistent, partial, and potentially misleading public disclosures.
Scope decision table (practical triage)
| Question | If “Yes” | Why it matters |
|---|
| Did revenue exceed €750m in each of the last two financial years? | Proceed to entity tests | Threshold in Accounting Directive Art. 48b(1) |
| Is the UPE in the EU (or is there an EU standalone undertaking)? | EU UPE/standalone likely reports | Direct obligation under Art. 48b(1) |
| Is the UPE non‑EU but has EU medium/large subsidiaries or qualifying branches? | EU entities may be obligated to publish | “Pull‑in” mechanism under Art. 48b(4)–(5) |
| Does the group operate only in one Member State and no other jurisdictions? | Possible exemption | Mandatory exemption under Art. 48b(2) |
| Is the group already publishing a CRD Art. 89 report that covers all activities? | Possible exclusion (for credit institutions) | Mandatory exclusion under Art. 48b(3) |
What must be disclosed in a Public CbCR report (data fields and jurisdiction split)
The content requirements sit in Accounting Directive Art. 48c(2). They are narrower than OECD CbCR, but still enough to generate reputational narratives if not curated and explained.
Required data fields (what the public will see)
For each in-scope jurisdiction line, the report includes:
- Nature of activities
- Number of employees (FTE)
- Revenues (including related-party transactions; computed per Accounting Directive Art. 48c(2)(d))
- Profit or loss before income tax
- Income tax accrued (the current tax expense recognised on taxable profits or losses; it must not include deferred taxes or provisions for uncertain tax liabilities — Accounting Directive Art. 48c(2)(f))
- Income tax paid (cash tax; can include certain withholding taxes paid by others on behalf of group members — Accounting Directive Art. 48c(2)(g))
- Accumulated earnings (as defined in Accounting Directive Art. 48c(2)(h))
It also includes identifying information such as the name of the reporting undertaking, financial year, currency, and (for certain jurisdictions) lists of subsidiaries (Accounting Directive Art. 48c(2)).
Jurisdictional breakdown: EU vs lists vs “rest of world”
Public CbCR requires different granularity than OECD CbCR:
- Always separate: each EU Member State
- Separate: jurisdictions on the EU list of non‑cooperative jurisdictions (Annex I) as of 1 March of the financial year
- Separate: jurisdictions on Annex II (“grey list”) that appear on 1 March of the financial year and on 1 March of the preceding financial year (i.e., two consecutive years)
- Aggregate: all other non‑EU jurisdictions into a single “rest of world” line
(See Accounting Directive Art. 48c(5).)
WarningBuild a control around the “as of 1 March” list logic. Misclassifying an Annex I/II jurisdiction can cause a filing that is technically non-compliant and, more importantly, may look like deliberate obfuscation.
Where the numbers usually come from (and where they commonly break)
A robust operating model maps each disclosure field to a data owner and source system:
| Field (Public CbCR) | Typical source | Common breakpoints |
|---|
| Revenues (incl. related-party) | Consolidation system / management reporting | Intercompany eliminations vs “by jurisdiction” attribution |
| P/L before tax | Consolidation + local statutory bridges | Permanent vs temporary differences misunderstood by non-tax readers |
| Current tax accrued | Tax provision (current portion) | Blended tax rates, true-ups, uncertain tax positions classification |
| Cash tax paid | Cash tax tracker / treasury | Withholding taxes, cross-border settlements, late payments |
| Employees (FTE) | HR systems | Allocation for mobile employees, shared service centers |
| Accumulated earnings | Local statutory accounts / consolidation | Multiple GAAPs, dividend flows, M&A history |
TipEven though the Directive allows certain alignment with DAC Annex III reporting instructions (Accounting Directive Art. 48c(3)), stakeholders won’t care which instruction set you used unless you can explain it consistently. Document your choices and apply them year-on-year.
When and how to publish (deadlines, registers, websites, and iXBRL)
Effective dates: why FY 2025 is the “first real year” for many groups
At EU level, Member States must apply Public CbCR rules at the latest for financial years starting on or after 22 June 2024 (Accounting Directive Art. 48g). For most calendar-year groups, that points to:
- First in-scope year (typical): FY 2025 (1 Jan 2025 – 31 Dec 2025)
- Publication deadline: within 12 months of year end → 31 Dec 2026
The 12‑month rule is in Accounting Directive Art. 48d(1).
NoteEarly-adopter jurisdictions exist. Because Art. 48g sets an “at the latest” date, some Member States chose earlier application dates in national law (for example, Romania has been cited as applying from FYs starting on/after 1 Jan 2023, and Croatia from FYs starting on/after 1 Jan 2024). If you have entities there, validate your first reporting year locally rather than relying on the “FY2025 first year” rule of thumb.
Publication channels and retention
The report must generally be:
- filed in the relevant national register (company law filing), and
- made accessible on the undertaking’s website,
free of charge, in at least one EU official language, and kept available for at least five years (Accounting Directive Art. 48d).
A Member State may allow a register-only approach if the register provides free, machine-readable access and the company website provides a link/notice (Accounting Directive Art. 48d(3)).
For reports on income tax information for financial years starting on or after 1 January 2025, the EU standardized template and electronic reporting format are set by Commission Implementing Regulation (EU) 2024/2952. In short: XHTML with embedded Inline XBRL (iXBRL) tags using the Commission’s Public CbCR taxonomy.
Operationally, this changes project planning:
- You are not just compiling a table—you are producing a digitally tagged disclosure
- Data, narrative, and sign-offs must be ready early enough to support tagging, validation, and register filing
NoteIf you already run ESEF (listed issuers) or CSRD digital reporting workflows, reuse governance and tooling where possible—but don’t assume tax data definitions match financial reporting taxonomies.
What is actually tagged (and what is optional) under Implementing Regulation 2024/2952
If you are building an iXBRL workplan, the key practical point is that the regulation distinguishes between:
- Mandatory mark-ups: disclosures must be tagged using the core taxonomy elements listed in Table 2 of Annex IV, in line with Annex III marking-up and filing requirements; and
- Optional additional mark-ups: undertakings may additionally tag using Table 3 of Annex IV.
This leads to a practical readiness checklist:
- Map each required Public CbCR data field to a taxonomy element (start with the Table 2 set).
- Decide whether any Table 3 (optional) tags add value (or create more review overhead).
- Build validations into the timeline (XHTML well‑formedness, iXBRL embedding, required tags present, consistent units/currency).
- Do an “acceptance test” with your target register filing workflow before the statutory deadline.
Governance, responsibility, and the auditor “presence check”
Member States must impose responsibility on the administrative/management/supervisory bodies, and (where a statutory audit is required) the auditor must state whether the report was required and whether it has been provided/published as required (Accounting Directive Arts. 48e–48f).
That means EU Public CbCR becomes part of the annual reporting perimeter—even if tax teams own the content.
The safeguard clause: can you delay sensitive disclosures?
Accounting Directive Art. 48c(6) includes an option for Member States to permit temporary omission of certain information where disclosure would be seriously prejudicial to the commercial position of the undertaking.
Key features practitioners should operationalize:
- Omitted information must be disclosed in a later report, and the deferral cannot exceed five years (Accounting Directive Art. 48c(6)).
- No omission is allowed for information pertaining to tax jurisdictions included in Annex I and Annex II (Accounting Directive Art. 48c(6)).
- Member States may implement stricter rules (shorter deferral periods or narrower eligibility).
- In practice, you should assume regulators and stakeholders will expect a clear justification and a re-publication calendar.
WarningDo not treat the safeguard clause as a blanket “competitiveness exception.” It is a narrow mechanism and can backfire reputationally if used to omit information that external readers consider central (e.g., profits and taxes in high-profile jurisdictions).
TipCreate a “safeguard dossier” template: (i) business rationale, (ii) legal basis in the relevant Member State, (iii) exact fields omitted, (iv) planned re-disclosure year, and (v) communications guidance. This reduces last‑minute escalation and inconsistent decisions.
How to prepare for Public CbCR (a practical implementation playbook)
Public CbCR is easiest when treated as an annual reporting product with a repeatable process, not a one-off compilation exercise.
Step 1: Confirm scope early (and centralize the decision)
Recommended timing: before year end for the first in-scope year.
- Confirm the two-year €750m revenue test and the “report for the latter year” mechanic (Accounting Directive Art. 48b(1))
- For non‑EU parents, assess EU subsidiaries’ “medium/large” status by Member State (national transposition can affect sizing)
- Decide whether to use a proxy approach (single parent-prepared report) to avoid multiple EU filings (Accounting Directive Art. 48b(6) mechanics)
Step 2: Decide your “definition set” (Public CbCR-native vs DAC-aligned)
Accounting Directive Art. 48c(3) allows Member States to permit use of DAC Annex III instructions for certain items. The most important operational decision is whether your Public CbCR will:
- follow Public CbCR-native definitions (as drafted in Chapter 10a), or
- be DAC-aligned for consistency with confidential CbCR and internal tax risk processes
Decision Criteria
- 01Choose a DAC-aligned approach when you already have mature DAC4 CbCR controls and want consistent narratives across confidential and public reporting.
- 02Choose a Public CbCR-native approach when DAC4 processes are decentralized or when local statutory/management reporting is a stronger data foundation.
- 03Either way, document definitions and stick to them year-on-year to avoid perceived ‘moving targets’ in public disclosures.
Step 3: Build a reconciliation and “story” layer (before you publish)
The Directive does not require a reconciliation to consolidated financial statements, but in practice you need a defensible bridge for internal sign-off and external questions.
Minimum controls most groups implement:
- Revenue and PBT tie-outs to consolidation (at least at a high level)
- Current tax accrued tie-out to the current tax provision
- Cash tax paid tie-out to treasury/cash tax tracker, with a withholding tax protocol
- A variance analysis for “optics outliers” (e.g., low accrued tax in profitable jurisdictions)
Step 4: Prepare narrative disclosures proactively
The Directive explicitly allows an overall narrative to explain material discrepancies between accrued tax and cash tax paid (Accounting Directive Art. 48c(7)). Use this to pre-empt predictable misinterpretations:
- timing differences (accrued vs paid)
- loss utilization, audits, prior-year settlements
- one-off items (restructuring, impairments)
- changes in footprint (acquisitions/disposals)
For reports for FYs starting on/after 1 Jan 2025 (Implementing Regulation (EU) 2024/2952), plan:
- taxonomy mapping and tagging rules (at minimum, the mandatory element set)
- validation checks and sign-offs
- register filing mechanics per Member State
- website publication workflow and 5-year retention controls (Accounting Directive Art. 48d)
Common Pitfalls to Avoid
- 01Mixing up current tax accrued vs cash tax paid and leaving large gaps unexplained—inviting incorrect ‘ETR’ narratives.
- 02Failing the Annex I/Annex II ‘as of 1 March’ logic and incorrectly aggregating jurisdictions that must be disclosed separately.
- 03Underestimating non‑EU ‘pull-in’ risk: multiple EU subsidiaries/branches publishing partial reports because the parent won’t provide data.
- 04Starting iXBRL tagging late—turning a solvable data exercise into a missed statutory publication deadline.
- 05Changing definitions year‑to‑year without a documented rationale, creating inconsistency that external readers will interpret as manipulation.
Practical Examples (with numbers)
Example 1: EU-headed calendar-year group—first report for FY 2025, publish by 31 Dec 2026
Facts
- UPE is established in an EU Member State.
- Consolidated revenue:
- FY 2024: €820m
- FY 2025: €860m
- Threshold met in both FY2024 and FY2025 → in scope to draw up a report for FY2025 (the latter of the last two consecutive financial years) (Accounting Directive Art. 48b(1)).
- EU-level “latest” commencement: FYs starting on/after 22 Jun 2024 → first calendar-year in-scope FY is typically 2025 (Accounting Directive Art. 48g).
- Publication deadline: 12 months after 31 Dec 2025 → 31 Dec 2026 (Accounting Directive Art. 48d(1)).
Illustrative Public CbCR extract (€, millions; employees = FTE)
| Jurisdiction | Revenues | P/L before tax | Current tax accrued | Cash tax paid | Accum. earnings (EOY) | Employees |
|---|
| Germany | 1,200 | 120 | 32 | 28 | 500 | 2,000 |
| France | 900 | 60 | 15 | 18 | 220 | 1,400 |
| Annex I jurisdiction (separate line) | 40 | 10 | 0 | 0 | 30 | 40 |
| Rest of world (aggregated) | 3,500 | 400 | 90 | 110 | 1,800 | 6,000 |
What the tax team should flag before publication
- France shows cash tax paid > accrued. Without context, readers may assume an error.
- Add a narrative note (permitted under Accounting Directive Art. 48c(7)) such as: “Cash tax includes €5m settlement of prior-year audit assessments.”
Example 2: US-headed group with a large EU subsidiary—why proxy publication matters
Facts
- UPE is in the United States (non‑EU).
- Consolidated revenue:
- FY 2024: €5.2bn
- FY 2025: €5.4bn
- EU footprint: a large subsidiary in Ireland and another EU branch that meets the local turnover trigger.
- Parent is reluctant to publish globally.
Option A (recommended where feasible): proxy publication
Parent prepares a single compliant Public CbCR report and designates the Irish subsidiary to publish it, meeting the conditions in Accounting Directive Art. 48b/48d (free public access, machine readable, EU language, within 12 months). Outcome: one consistent EU report.
Option B (high-risk): parent refuses to provide information
Irish subsidiary must publish what it can and include a statement that the UPE did not provide required information (Accounting Directive Art. 48b(4)). This can produce an incomplete “rest of world” line and inconsistent disclosures across Member States.
Illustrative “partial” outcome (what investors will see)
| Jurisdiction | Revenues | P/L before tax | Current tax accrued | Cash tax paid | Employees |
|---|
| Ireland | 600 | 90 | 9 | 6 | 850 |
| Rest of world (aggregated) | Not fully available | Not fully available | Not fully available | Not fully available | Not fully available |
Accompanied by a statement: “The ultimate parent undertaking did not make the necessary information available.”
WarningIf you are a non‑EU parent, refusing to provide data does not eliminate disclosure—it shifts disclosure to EU entities, increases inconsistency risk, and can be worse reputationally than a controlled, centrally prepared report.
Example 3: Accrued vs paid tax optics—how timing differences create “false low tax” narratives
Assume a jurisdiction shows:
- P/L before tax: €100m
- Current tax accrued (current tax expense): €20m
- Cash tax paid: €5m
A simplistic reader may compute a “cash ETR” of 5% and claim low taxation. But if the €15m difference reflects:
- €12m paid next year due to instalment mechanics, and
- €3m of tax credits utilized against current tax,
then the disclosure is economically consistent—just poorly explained.
A concise narrative note could say:
“Cash tax paid reflects instalment timing and utilization of €3m of credits; the current tax accrued is aligned to taxable income for the year.”
This type of narrative reduces controversy risk without changing any numbers.
Glossary:
FAQ: EU Public CbCR (Directive 2021/2101)
1) What is EU Public CbCR?
EU Public CbCR is a requirement for certain large undertakings to publicly disclose a “report on income tax information” by jurisdiction under Directive (EU) 2021/2101 and the Accounting Directive Articles 48a–48h.
2) How is Public CbCR different from OECD (tax authority) CbCR?
OECD/DAC4 CbCR is confidential and exchanged between tax authorities; EU Public CbCR is public, has a different data set (Accounting Directive Art. 48c), and allows aggregation of most non‑EU jurisdictions into “rest of world.”
3) Who is in scope for EU Public CbCR?
Generally, EU UPEs/standalone undertakings and certain non‑EU groups with qualifying EU subsidiaries/branches are in scope when revenue exceeds €750m in each of the last two consecutive financial years and the report is prepared for the latter year (Accounting Directive Art. 48b). Credit institutions already reporting under CRD Article 89 may be excluded, depending on how the rule applies to the group (Accounting Directive Art. 48b(3)).
Per Accounting Directive Art. 48c(2), disclosures include activities, employees, revenues, profit/loss before tax, current tax accrued (excluding deferred tax and provisions for uncertain tax liabilities), cash tax paid, accumulated earnings, and certain identifying information.
5) When is the first reporting year for calendar-year groups?
At EU level, Member States must apply the rules at the latest for financial years starting on/after 22 June 2024 (Accounting Directive Art. 48g), so many calendar-year groups start with FY 2025. However, some Member States chose earlier local effective dates, so your first reporting year can be earlier depending on where you operate.
6) When is EU Public CbCR publication due?
The report must be published within 12 months after the balance sheet date (Accounting Directive Art. 48d(1)). For FY 2025 calendar-year filers, this is typically 31 Dec 2026.
7) Where must the report be published?
It must generally be filed in the national register and made available on the undertaking’s website, free of charge, in at least one EU official language, and kept accessible for five years (Accounting Directive Art. 48d), subject to Member State options for register-only publication.
8) Do we need iXBRL/XHTML tagging for Public CbCR?
For reports for financial years starting on/after 1 Jan 2025, Implementing Regulation (EU) 2024/2952 applies and sets the common template and XHTML with Inline XBRL (iXBRL) mark-up requirements.
Member States may permit temporary omission where disclosure would be seriously prejudicial, with later re-disclosure and a maximum deferral period under the Directive’s framework (Accounting Directive Art. 48c(6)). Information for Annex I/II listed jurisdictions cannot be omitted, and national rules can be stricter—so local legal review is essential.
10) What’s the biggest practical risk for multinational groups?
The biggest risk is publishing technically correct numbers that are easily misinterpreted (especially current tax accrued vs cash tax paid) without a narrative and without robust controls—creating avoidable reputational and controversy exposure in the first publication cycle.
Borys UlanenkoCEO of ArmsLength AI
