Public Country-by-Country Reporting (Public CbCR) introduces a new level of tax transparency for certain multinational groups operating in Ireland. For groups within scope, including those meeting the €750 million consolidated revenue threshold, tax and financial information that was previously reported confidentially will now become publicly accessible.
This is not simply another compliance requirement. It creates a new level of scrutiny around how multinational groups report profits, tax and economic activity across different jurisdictions.
What Public CbCR makes public
For groups within scope, Public Country-by-Country Reporting will expose information such as:
- Profit before tax
- Tax accrued and tax paid
- Employee numbers
- Turnover and activities by jurisdiction
- Accumulated earnings
Who does Public CbCR apply to?
Public CbCR broadly applies to multinational groups with consolidated annual revenues exceeding €750 million for each of the previous two consecutive financial years.
The rules can apply to EU-parented multinational groups, as well as certain EU subsidiaries and branches of multinational groups headquartered outside the EU.
For Irish businesses that form part of a larger international group, it is therefore important to establish whether the wider group falls within scope and which entity will be responsible for meeting the reporting requirements.
Who will be reading it?
And the audience isn’t just the tax authorities.
Investors. Analysts. Regulators. Media. Employees. The public.
That significantly changes the context in which the information is being reported.
The question is bigger than compliance
The question for CFOs, Tax Directors and Finance leaders is therefore bigger than: “Can we comply?”
The more important question is: “What will our numbers say about us, and how will others interpret them?”
Public CbCR vs existing Country-by-Country Reporting
Country-by-Country Reporting itself is not new. Large multinational groups have already been required to provide certain jurisdiction-level information to tax authorities under existing CbCR rules.
The significant difference with Public CbCR is accessibility.
Instead of this information remaining within tax administrations, specified tax and financial information will become publicly available. That means businesses need to consider not only whether the figures are technically correct, but also how those figures may be interpreted by stakeholders outside the tax function.
When the first reports are due
The Irish Public CbCR requirements apply to financial years beginning on or after 22 June 2024.
For groups with a 31 December year-end, this means the first relevant reporting period will generally be the financial year ending 31 December 2025, with the first Public CbCR report due by 31 December 2026.
For businesses within scope, the deadline is therefore approaching quickly.
What to do now
- Identify exactly which entities are in scope
- Confirm which group entity is responsible for reporting
- Validate the underlying tax and financial data
- Challenge inconsistencies between systems and jurisdictions
- Strengthen governance and controls
- Consider the potential reputational impact
- Prepare the narrative around the numbers
Because once the data is public, you don’t control the questions it generates.
Public CbCR should therefore be viewed not just as a tax compliance issue, but as a board-level tax governance and reputational issue.
Is your organisation ready?
The era of private tax reporting is changing.
The question is: will your organisation be ready when the numbers go public?
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FAQS
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What is Public Country-by-Country Reporting?
Public Country-by-Country Reporting, or Public CbCR, requires certain large multinational groups to make specified tax and financial information publicly accessible.
What is the €750 million Public CbCR threshold?
The regime broadly applies to multinational groups with consolidated revenue exceeding €750 million for each of the previous two consecutive financial years.
What information does Public CbCR make public?
Information disclosed can include profit before tax, tax accrued and paid, employee numbers, turnover, activities by jurisdiction and accumulated earnings.
What is the difference between CbCR and Public CbCR?
Traditional Country-by-Country Reporting involves information being provided to tax authorities. Public CbCR requires specified information to become publicly accessible, creating a wider audience for the data.
When is the first Public CbCR report due in Ireland?
For groups with a 31 December year-end, the first reporting period will generally relate to the year ending 31 December 2025, with publication required by 31 December 2026.
Does Public CbCR apply to Irish subsidiaries of overseas groups?
It can. Certain Irish subsidiaries and branches of multinational groups headquartered outside the EU may have obligations under the Public CbCR regime, depending on the structure and size of the wider group.
Who can see Public CbCR data?
The audience is not limited to tax authorities. Investors, analysts, regulators, media, employees and members of the public may all be able to access the information.
