Country-by-Country Reporting: Transparency, Compliance and Strategic Considerations for MNEs

CbCR has become a significant and unavoidable compliance obligation. Beyond compliance, it also presents reputational and strategic challenges with the new requirement to publicly disclose CbCR information.

Compliance Considerations

CbCR is typically filed with the tax authority of the ultimate parent entity’s jurisdiction. Subsidiaries must often notify local tax authorities of the reporting entity. This is also the case for the Netherlands. Non-compliance (filing or the notification) can lead to significant fines.

Strategic implications and best Practices

• Risk Management: CbCR is a trigger for tax audits; groups should reconcile CbCR with transfer pricing documentation (Master File, Local Files).
• Transparency vs Confidentiality: Public disclosure may influence corporate reputation and ESG ratings.
• Tax Governance: CbCR aligns with growing demands for responsible tax behavior and governance frameworks.
• Future Developments: The trend is toward broader disclosure and possible alignment with Pillar Two (global minimum tax reporting).

CbCR is more than a compliance exercise

CbCR is more than a compliance exercise, it is a transparency tool that shapes how tax authorities, investors, and the public perceive a MNEs tax profile. MNEs should not only aim for accurate and timely filings but also leverage CbCR data to strengthen tax governance, mitigate risks and support a responsible corporate narrative.

Milestones & Dutch Deadlines:

For the Netherlands, below is a high-level overview of the upcoming requirements and key dates:

• 31 December 2025: NL CbCR notification deadline for FY2025 (calendar‑year groups).
• 31 December 2025: NL CbCR due for FY2024 (if the reporting entity files in NL and FY ended 31 Dec 2024).
• 31 December 2026: Public CbCR publication due for FY2025 (for groups with FY starting 1 Jan 2025). 

Can we help you?

At aaff we like to be of significance. Our experts from international tax can assist you with analyzing the legal requirements for your group or individual entities, creating Country-by-Country reporting templates and focusing on the practical aspects of preparing the Country-by-Country report.  Would you like to discuss the practical implications or need help with the preparation and filing of the Country-by-Country report or the notification, please contact us.