Almost two-thirds (59%) of corporate tax transparency reports published by large multinationals in connection with the EU Public Country-by-Country Reporting (pCbCR) Directive are good, solid attempts to be open and honest.

However, there are wide national variances. The frequency of good application of the EU pCbCR requirements was substantially above average among business headquartered in the UK (at 78%) and Japan (76%), and substantially below average among business headquartered in the US (42%) and Switzerland (44%).

The Fair Tax Foundation’s pCbCR Resource Hub includes a running assessment of corporate tax transparency reports from around the world, as stipulated by countries implementing the EU pCbCR Directive. We have now sourced and analysed 152 reports. Which is by some way, the most extensive analysis published globally to date. Reports connected to a year-end September 2024 are now beginning to emerge (Pepco Group and Apple Inc), and we have seen the first EU pCbCR reports emerge connected to business in Mexico (Grupo Bimbo) and Russia (Lukoil).

Whilst the majority of multinationals that are impacted by the EU pCbCR Directive have implemented these new tax transparency rules with integrity and courage, there is a substantial minority of business (especially those based in the United States and Switzerland) that have opted to do little or nothing.

The gap between the corporate progressives and the corporate laggards has again widened since our previously reported analysis. As presented in June and July 2025.

The overall level of solid compliance has fallen to 59%, driven largely by more businesses from the United States opting to provide data on a ‘Romania-only’ basis (such as Apple and Mondelez).

Our latest data analysis reveals that:

• Almost two-thirds (59%) of corporate pCbCR reports are good, solid attempts to implement legislation driven by the EU pCbCR Directive. Most recently demonstrated by Pepco Group.
• However, in 7% of instances, business have opted to confine disclosures to EU designated tax havens (such as Amgen), and refuse to be transparent about their impact across EU Member States.
• Worse still, a quarter of parent companies (27%) will not share global CbCR data with their Romanian subsidiaries and are effectively refusing to implement the legislation. The proportion of US-business that opt for this ‘Romania-only’ approach (44%) now exceeds the percentage that embrace pCbCR compliance solidly (42%). We have previously listed and commended the twenty-six US-multinationals that have shown welcome progression on tax transparency.
• The frequency of good application of the EU pCbCR requirements was substantially above average among business headquartered in the UK (at 78%) and Japan (76%). It was substantially lower than average among business headquartered in the US (42%) and Switzerland (44%).
• A significant minority of business (14%) embraced the spirit as well as the letter of the legislation, and progressed full public country-by-country reporting and/or voluntarily progressed the EU pCbCR ahead of legislative requirements. Most recently, Coloplast.
• The pharmaceuticals sector had a significantly below average rate of compliance: with just three of the ten companies (30%) showing solid implementation of the directive, whilst five (50%) opted for the ‘Romania-only’ option. The automotive and food & beverages sectors also stood out as laggards. Conversely, the industrials sector demonstrated above average levels of compliance and responsibility, as did chemicals, communications and consumer goods.

Background

The EU public Country-by-Country Reporting (pCbCR) Directive has begun to impact large multinationals around the world. The directive requires large multinational companies that have a substantial presence in Europe to publicly share key financial information on their operations in each EU Member State and a designated list of tax havens. In the main, the Directive will lead to major new corporate tax disclosures in 2026, based on 2025’s financial data. However, Romania opted to implement the EU Directive much earlier than other Member States, with data relating to 2023 starting to emerge at end 2024. We are now seeing the first EU pCbCR disclosures come to light.

An oddity in the way Romania has implemented the Directive means that only multinationals with significant operations in Romania, but that are headquartered outside of the EU, are impacted as yet – i.e., businesses with an ultimate parent entity in the US, Switzerland, Japan, the UK, etc.

We have conducted extensive online searches to find these first EU pCbCR public reports and have identified 152 to date. There is no central repository of reports. Research was not as simple as might be hoped as the Romanian business register is not yet operational as a public repository of such information. Furthermore, there are no penalties in Romania for neglecting to implement the legislation as required. Which means, we suspect, that there are a sizeable minority of business who have simply opted to ‘ignore’ the legislation or are waiting to see how their competitors respond. For example, we have not, as would be expected, found returns from the likes of Amazon, IBM* and Samsung. This needs to be borne in mind in the analysis that follows: whatever their rating, at the very least, all of the 152 companies identified as producing information on their website in connection with the EU pCbCR Directive have at least acknowledged its existence in some way.

Note – all 152 assessed reports are driven by either: i) mandatory capture of multinationals by Romania’s early implementation of the EU pCbCR Directive; or, ii) explicit, early voluntary implementation of the Directive by multinationals. Many other businesses voluntarily already meet, or surpass the EU pCbCR requirements. Including a good number of Fair Tax Mark accredited businesses, such as Fortum (Finland), Iberdrola and Repsol (Spain), Mace and SSE (UK) and Mundys (Italy). However, they have not been including in this analysis as they do not explicitly claim that their reporting currently meets the EU pCbCR standard.

We hope to update this research on a regular basis, and plan to make it freely available to all business that are involved in our Fair Tax Mark certification scheme and our Tax Responsibility and Transparency benchmarking index. If you would like to engage with us on this work please reach out to [email protected]

For more detail and the very latest data, visit the Fair Tax Foundation pCbCR Resource Hub.

* Note: after publication of this article, an anonymous individual forwarded a link to IBM’s EU pCbCR return (which discloses ‘Romania-only’). However, this document cannot be found, to the best of our ability, via standard web searches and is essentially invisible to the public. We will update our database accordingly.