What Is Country-by-Country Reporting (CbCR)?
Country-by-Country Reporting (CbCR) is a transfer pricing disclosure obligation under which large multinational groups report key financial data to tax authorities for each jurisdiction.
Also known as: CbC reporting, Country-by-Country Report.
How CbCR (Country-by-Country Reporting) works
Country-by-Country Reporting applies to multinational enterprise groups whose total consolidated group revenue reaches the threshold set in law, EUR 750 million under the EU rules, and requires the ultimate parent entity, or in some cases another group entity, to file a report allocating revenues, profits, taxes and activity indicators across every tax jurisdiction. Under Council Directive (EU) 2016/881 (DAC4), the report is due within 12 months of the last day of the reporting fiscal year and covers revenues, profit or loss before income tax, income tax paid and accrued, stated capital, accumulated earnings, number of employees and tangible assets. Tax administrations exchange the reports automatically and use the data for high-level transfer pricing and base erosion risk assessment rather than as a basis for assessing tax directly. A separate Directive (EU) 2021/2101 requires groups above EUR 750 million in revenue for two consecutive years to publish an income tax information report, at the latest from financial years starting on or after 22 June 2024, while thresholds and filing mechanics outside the EU are subject to local rules.
CbCR (Country-by-Country Reporting) vs Transfer Pricing
Unlike transfer pricing documentation such as the master file and local file, Country-by-Country Reporting gives aggregate figures per jurisdiction rather than an analysis of individual intercompany transactions and their arm's length pricing.
Example
Illustrative example: A software group headquartered in Country A, with consolidated revenue above the applicable threshold, has subsidiaries in Country B and Country C. The parent files one report listing, for each of the three jurisdictions, revenues, pre-tax profit, income tax paid and accrued, employees and tangible assets, and Country A transmits the report to Countries B and C under exchange agreements. A remote founder's two-company structure with revenue far below the threshold would generally have no CbCR filing, although other transfer pricing documentation rules may still apply.
Common misconception
Myth: Any company with foreign subsidiaries or cross-border clients must file a country-by-country report.
Reality: Country-by-Country Reporting generally applies only to multinational groups at or above the revenue threshold set in national law, which the EU rules fix at EUR 750 million in consolidated group revenue.
Frequently asked questions
Who has to file a CbC report?
Country-by-Country Reporting generally falls on the ultimate parent entity of a multinational group with consolidated revenue of at least EUR 750 million, with secondary filing by a local entity in some cases, subject to national implementation.
What does a country-by-country report contain?
A country-by-country report contains, for each tax jurisdiction, revenues, profit or loss before income tax, income tax paid and accrued, stated capital, accumulated earnings, number of employees and tangible assets, plus a list of constituent entities and main activities.
Related terms
- Transfer Pricing — Documentation framework CbCR complements, often confused with it
- Base Erosion and Profit Shifting (BEPS) — OECD project which introduced CbCR under Action 13
- Directive on Administrative Cooperation — EU legal basis for CbCR exchange (DAC4)
- Automatic Exchange of Information (AEOI) — Channel through which reports reach other tax authorities
- Pillar Two — Uses the same EUR 750 million group revenue threshold
Related guides
- Global tax reform and US digital nomads — Context on global corporate tax transparency reforms
Sources
Last verified: 2026-10-08. This entry is general information, not tax or legal advice; rules vary by country and change over time.
