Plain English
A one-page-per-country scoreboard filed with the parent's tax authority and exchanged with others. It is not used to compute an adjustment directly — it is used to decide who to audit.
Technical definition
The third tier of BEPS Action 13, requiring MNE groups with consolidated revenue at or above EUR 750 million to report aggregate data on revenues, profit before tax, tax paid and accrued, stated capital, accumulated earnings, employees and tangible assets by jurisdiction, plus a list of entities and activities.
Why it matters
It is the highest-visibility transfer pricing filing there is, and increasingly it is public: the EU public CbCR directive requires disclosure for financial years starting from mid-2024 in many member states.
How it works in practice
- 01Test the EUR 750 million consolidated revenue threshold for the preceding year.
- 02File notifications in each jurisdiction identifying the reporting entity.
- 03Prepare Tables 1, 2 and 3 from a consistent data source.
- 04File within twelve months of the reporting fiscal year end.
- 05Review the output for risk indicators before filing.
Worked example
Reading your own report
A jurisdiction shows 4% of group employees, 2% of tangible assets, and 31% of profit before tax. Nothing about that is unlawful, but it is precisely the pattern risk-assessment tools flag. The group should be able to explain it — typically through intangible ownership with genuine DEMPE substance — before the question arrives.
Common mistakes
- Inconsistent data sources between years.
- Missing notification deadlines, which carry separate penalties.
- Treating CbCR as a compliance exercise rather than a risk signal to read first.
Audit red flags
- High profit with negligible employees in a jurisdiction.
- Tax accrued materially different from tax paid without explanation.
Documentation & data
Documents to hold
- CbC report Tables 1-3.
- Notification filings.
- Data source and methodology memo.
Data you need
- Consolidation system extract by entity and jurisdiction.
- Headcount data on a consistent definition.
- Tax paid on a cash basis.
Who owns this internally: Group tax reporting, with data from group consolidation and HR.
Jurisdiction notes
- European Union
- Public CbCR under Directive (EU) 2021/2101 requires publication of certain data, separate from the confidential exchange regime.
- Global
- CbCR data also feeds the Pillar Two transitional safe harbours, raising the stakes on data quality.
Notes by role
CFOs & finance leaders
Read your own CbC report as an outsider would before you file. If a pattern needs explaining, prepare the explanation now, not in year three of an audit.
Frequently asked
- Can a CbC report be used to make an adjustment directly?
- The standard states it should not be used as a substitute for a detailed transfer pricing analysis or to make formulary apportionment-based adjustments.
Sources & status
- Primary source
OECD Transfer Pricing Guidelines, Chapter V and Annex III
OECD, 2022
- Primary source
Directive (EU) 2021/2101 on public country-by-country reporting
European Union, 2021
Reference material only, not advice on a specific fact pattern. Reviewed 2026-06-30.
Careers
How this shows up in the job
CbCR sits at the junction of tax, data and reporting. Data-fluent candidates get pulled into it early.
Careers in transfer pricing