EU Public CbCR: what MNCs with a Swiss presence need to do before 31 December

On 24 November 2021, the EU adopted Directive (EU) 2021/2101, introducing public country-by-country reporting (“Public CbCR”) for in-scope multinational groups. The first financial year (“FY”) 2025 reports for calendar-year groups generally due by 31 December 2026.

Country-by-Country Reporting (“CbCR”) provides tax authorities with information on a multinational group’s revenue, profits, taxes and business activities across jurisdictions. EU Public CbCR brings specified information into the public domain, extending visibility to investors, media and other stakeholders.

For Swiss-headquartered groups, the EU footprint is the key trigger. Groups exceeding EUR 750 million consolidated revenue in each of two consecutive financial years fall within scope where they have qualifying EU subsidiaries or branches. Those EU entities carry the publication obligation, subject to applicable exemptions. If the parent does not supply the required information, the local entity must publish the information available and disclose that the parent did not provide it.

Foreign-headquartered groups with Swiss operations are also affected where the group falls within EU Public CbCR: Swiss activities form part of the reporting perimeter, although their figures may be aggregated with other non-EU jurisdictions. Swiss presence alone does not trigger the obligation.

Swiss CbCR status does not determine EU Public CbCR scope. Switzerland’s confidential regime uses a CHF 900 million threshold, while EU Public CbCR uses EUR 750 million and different scope tests. The two obligations must therefore be assessed separately.

Non-compliance can result in penalties under the relevant Member State’s legislation. Statutory auditors must also state whether publication was required and made, making missing publication visible beyond the tax function.

What becomes public?

• Revenue
• Profit or loss before tax
• Income tax paid and accrued
• Employees
• Accumulated earnings

Data is disclosed separately for EU Member States and specified EU-listed jurisdictions; remaining jurisdictions are generally aggregated. Confidential OECD CbCR reporting does not replace public disclosure.

When should groups act?

For calendar-year groups, the first financial year 2025 report is generally due by 31 December 2026. Check earlier application dates and, in some Member States, shorter deadlines set for local transposition.

Five priorities for readiness

1. Map the qualifying EU footprint

Identify which EU subsidiaries and branches meet the applicable scope conditions and where publication obligations arise. Assess EU Public CbCR scope separately from Swiss confidential CbCR obligations.

2. Check early-adopter rules and local deadlines

Confirm the first reporting year and publication deadline in each relevant Member State, including whether obligations have already arisen for earlier financial years.

3. Test whether existing OECD CbCR data converts to the EU format

Assess the existing data package against the common EU template and XHTML/iXBRL requirements, identifying gaps and necessary reconciliations.

Recommended approach: involve Tax, Finance/consolidation and IT, and review consistency with other public reporting.

4. Review sensitive data for deferral eligibility

Assess whether commercially sensitive information qualifies for temporary omission where the relevant Member State permits it, taking account of local conditions and time limits.

5. Align with local statutory auditors

Coordinate with local statutory auditors on whether publication is required and made.

Recommended approach: assess a compliant centralized parent-publication route, establish management sign-off and prepare clear explanations of the business context behind the disclosures.