This year marks the first time that the Public CbCR publication deadline is added to the many other obligations and deadlines that companies face: the time when they must actually publish their report containing public corporate income tax information (Public Country-by-Country Report). In Hungary, the Public CbCR reporting deadline does not only affect Hungarian-headquartered parent companies – Hungarian subsidiaries of third-country multinational groups may also be subject to the requirement. The 31 May and 30 June 2026 deadlines are approaching rapidly, meaning that affected companies must act now. What are the key facts to know, and what practical questions should companies prepare for already?
The 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 the reporting obligation?
The Public CbCR must be prepared and published by companies and groups of companies whose consolidated revenue exceeds EUR 750 million (HUF 275 billion in Hungary) in two consecutive financial years. In the case of a corporate group, the obligation generally falls onthe ultimate parent entity. However, if the ultimate parent entity is not subject to EU jurisdiction, EU-based subsidiaries and branches may also become obliged. This means that a Hungarian subsidiary may become directly subject to the obligation if it has a non-EU parent company and the group’s consolidated revenue reaches the EUR 750 million threshold – even if such an obligation does not exist in the parent company’s country of residence.
What must the Public CbCR include?
The report must present, on a country-by-country basis, among others, the name of the company, the currency used, the revenues, the profit or loss before tax, the corporate income tax paid and accrued, the retained earnings, the number of employees, the list of group entities and the 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.
Which Public CbCR reporting deadline applies to whom?
The obligation applies for the first time to financial years starting on or after 22 June 2024. Accordingly, for companies with a calendar financial year, the first affected year ends on 31 December 2025. Based on this, the Public CbCR reporting deadline is as follows:
- for parent companies: 30 June 2026
- for standalone entities: 31 May 2026
The report must be made publicly available on the company’s website for at least five years.
Who is responsible?
The auditor is required to verify whether the report has been prepared and whether it complies with legal requirements. If the obliged company fails to file or publish the report, it may face consequences under the Hungarian Accounting Act. The executive officers and members of the supervisory board bear joint responsibility for compliance.
Steps to take before the Public CbCR reporting deadline
1. Identifying the obligated entities: Within the group, it must be identified which entity is obligated. If the ultimate parent entity is located outside the EU, the obligation of the Hungarian subsidiary may arise – considering the EUR 750 million consolidated revenue threshold.
2. Coordination with the parent company: In the case of a Hungarian subsidiary or branch of a third-country parent company, data requests must be initiated in time. The subsidiary or branch is required to prepare the report based on the data available to it even if the parent company does not cooperate. In such cases, the Public CbCR must be supplemented with a statement indicating that the ultimate parent entity did not provide the necessary information.
3. Assessing data sources: The report is typically compiled from the consolidated financial statements, internal CbCR reporting and local corporate income tax returns. These data sources recommended to be checked now for consistency and availability.
4. Preparation for reputational risks: After the Public CbCR reporting deadline, the data will be publicly accessible. Investors, business partners and the media will analyse how reported profits in each country compare to the corporate income tax actually paid.
5. Ensuring publication: The report must be prepared in a machine-readable format and made available on the company’s website for at least five years.
The tax consulting team of WTS Klient Hungary has more than two decades of experience in supporting the tax affairs of international corporate groups, including cross-border tax planning and structuring, taking into account EU regulations, bilateral tax treaties and the specific features of the Hungarian tax environment. If the Public CbCR reporting deadline affects you as well, and you need assistance in interpreting or fulfilling the obligation, please contact us with confidence.
This article is for general information purposes only and should not be considered as advice.
