Next May, most large companies will have to publish their first Public CbCR on their websites, i.e., a public report containing their corporate tax information that will now be accessible not only to tax authorities, but also to investors, competitors, the press, civil society organisations, and even consumers can see their tax practices. The new EU requirement goes beyond a simple administrative obligation: it also has a significant impact on companies’ operations, communications, and reputation. It is therefore advisable for the companies concerned to prepare for reporting in advance and to adapt their internal processes and data reporting practices accordingly.
What is Public CbCR?
Public CbCR is a public, country-by-country report containing the tax and financial information of multinational corporate groups. These companies have already provided similar data to tax authorities (CbCR), but until now, the data provided has been used exclusively for the internal control and risk analysis purposes of the tax authorities. Public CbCR, on the other hand, is a public document.
Who is subject to Public CbCR?
The reporting and disclosure obligation applies to companies and corporate groups with consolidated annual revenues exceeding EUR 750 million for two consecutive financial years. As a general rule, the ultimate parent company is responsible for submitting the report. However, if the parent company is not governed by EU law, then any EU-based subsidiaries or branches must also comply and publish the report themselves.
What must be included?
The Public CbCR must disclose, on a country-by-country basis, the following information:
- name of the ultimate parent undertaking or standalone entity
- relevant financial year and the currency used
- revenues generated
- profit or loss before tax
- corporate income tax paid
- corporate income tax accrued
- retained earnings
- number of employees
- list of group entities
- description of main business activities
The report must be prepared using a standard template provided by the European Commission and submitted in a machine-readable format. Alternatively, companies may use the structure defined in the existing CbCR guidance used for tax authority submissions.
When must it be published?
The EU Public CbCR Directive was published in December 2021 and implemented into Hungarian law in May 2023. The first financial years subject to the obligation are those starting on or after 22 June 2024.
The report must be prepared and published together with the annual or consolidated financial statements and made publicly available on the company’s website for at least five years. The relevant publication deadlines are:
- For parent companies: by the last day of the sixth month following the balance sheet date
- For standalone entities: by the last day of the fifth month following the balance sheet date
For companies with a regular calendar fiscal year, the end of the first reportable year will be 31 December 2025, and the reporting deadline:
- for parent companies: 30 June 2026
- for standalone entities: 31 May 2026
Who reviews the report and who is responsible?
The company’s statutory auditor is required to verify whether the report has been prepared and complies with legal requirements. Failure to publish or file the report may result in consequences under the Hungarian Act on Accounting. Responsibility for compliance lies jointly with the company’s executive officers and members of the supervisory board.
Why is this important for companies?
The EU’s goal with Public CbCR is to improve transparency in corporate tax practices – beyond tax authorities – to the public at large. Enhanced transparency is also a matter of corporate reputation. Publicly disclosed data can influence investor decisions, shape consumer perception, and impact public trust. Companies within scope should take steps now to ensure compliance for the 2025 financial year, including reviewing internal data collection, financial systems, and communication strategies.
The tax consulting team at WTS Klient Hungary has over two decades of experience supporting international corporate groups with cross-border tax planning and structuring. We provide tailored solutions that take into account EU regulations, bilateral tax treaties, and specific provisions of the Hungarian tax system. If you need assistance interpreting or complying with Public CbCR requirements, don’t hesitate to contact us.
This article is for general information purposes only and should not be considered as advice.
