Updates on Public Country-by-Country Reporting format

The European Commission adopted a template and electronic reporting format for presenting information on corporate income tax within the framework of Public CbCR. The primary objective of the regulation is to ensure the comparability of tax information reports, as required by Directive 2013/34/EU.

The report is structured into five main sections:

1. General information: details about the ultimate parent entity and the reporting currency;
2. Overview of information on a country-by-country basis: revenues, profits, taxes, and the number of employees;
3. List of subsidiaries and activities: the nature of activities conducted in each tax jurisdiction;
4. Omitted information: explanations for the possibility to temporarily omit information under certain conditions;
5. Optional explanations: justifications for discrepancies between taxes paid and accrued, if relevant.

The regulation will apply to Public CbC Reports for financial years beginning on or after 1 January 2025.

Recommendations from the Romanian authorities

In September, the Romanian authorities issued a statement on the website of the Ministry of Finance, providing guidance for taxpayers regarding the format to be used for publishing. Taxpayers can choose between the following options:

• Use the reporting instructions from Section III, Parts B and C of Annex III to Directive 2011/16/EU, which refers to the existing non-public CbCR format.

or

• Develop their own reporting format, ensuring that all required information, as per applicable accounting regulations, is included.

This clarification is important, as the first reporting financial year under Romanian Public CbCR legislation is 2023, while the template and electronic format set out by the EU Regulation will apply to reports covering financial years starting on or after 1 January 2025.

The first deadline in Romania is 31 December 2024 for groups with a calendar financial year ending in 2023.

The implementation of Public CbCR in Romania marks a significant step towards tax transparency for large multinational companies. Public CbCR obligations will run in parallel with the non-public CbCR obligations in Romania.