Fair Tax Foundation pCbCR research expands to 650 multinationals as Spanish filings surge
Greg Yates, senior ratings manager, Fair Tax Foundation
Chloe Almond, research analyst, Fair Tax Foundation
The Fair Tax Foundation have more than doubled the number of multinational enterprises covered by our research into implementation of the EU Public Country-by-Country Reporting Directive – from just over 300 in June 2026 to 650 at the end of September.
Our newly updated pCbCR Resource Hub now draws on 741 reports from 650 multinational enterprises (MNEs), providing our most extensive picture yet of how large businesses are responding to this landmark corporate tax transparency measure. The rapid expansion of the dataset has been driven principally by Spain, where a shortened filing deadline has brought forward a substantial wave of reports from companies with financial years ending in 2025.
The larger evidence base reinforces a divided picture. More than half (54%) of the reports covered by our research are at least good, solid attempts to be open and honest, with 13% of MNEs even going above and beyond the Directive’s requirements. However, we rate reporting as poor or partial in 46% of cases, and only a handful of companies show signs of improving after their first filing. There is significant scope for progress: just over 100 businesses say they intend to publish more data once reporting timelines align, which would lift the proportion of MNEs rated as good to 70% and reduce the group rated as poor or partial to 30%.
Spain transforms the reporting landscape
When we last updated this research at the end of June, we had analysed 383 reports from 302 MNEs, with most linked to Romania’s early implementation of the Directive. Three months later, the number of companies reviewed has risen to 650. Spain has overtaken Romania as the leading country where MNEs are being pushed to report, with 276 filings compared with 201 in Romania. Ireland’s law now accounts for 28 MNE reports and Croatia’s for 24, while some companies have filed in more than one jurisdiction.
Spain’s rules require reports to be filed within just six months of the balance sheet date. This shortened deadline has pushed many companies with financial years ending in 2025 – including those headquartered in Spain – to publish for the first time during summer 2026. One of Europe’s major economies specifying an accelerated compliance timeline has added considerable momentum to the recent flow of first reports and altered the composition of our dataset.
Our previous updates (1, 2, 3, 4 and 5) have mainly drawn on reports by non-EU MNEs headquartered in the likes of Japan, Switzerland, the UK and USA, brought into scope through their substantial presence in Romania or a second early-adopting EU country, Croatia. But the number of reports we have detected by MNEs headquartered in Spain has now risen sharply, from just eight in June to 53 by the end of September.
A majority report well – but poor practice has increased
The headline finding remains encouraging: most MNEs are making serious efforts to apply the new transparency requirements in the spirit intended. However, the proportion rated as at least good, solid attempts has fallen from 58% in June to 54% in September. Correspondingly, the share of poor or partly implemented reporting has risen from 42% to 46%. The expanded sample suggests that the earliest reporters were, on average, a little more willing or better prepared to embrace the purpose of the legislation than some of the businesses now following them.
Within the group rated as poor, the pattern has also changed. Some 39% of all MNEs reviewed disclose information only for the country in which the report is filed – up from 32% in June. This approach denies stakeholders the more rounded view of an MNE’s economic activity and corporate income tax contribution that public Country-by-Country Reporting is intended to provide.
Notably, just over 100 businesses state that they intend to publish more data in the near future when reporting timelines are better aligned. If they follow through, the proportion of MNEs we rate as good would rise to 70% – a significant 16 percentage point increase – while the proportion rated as poor or partly implementing would fall to 30%.
Three recurring explanations for weak reporting
Some MNEs explain publicly why their filings fall short. Across the reports we rated as poor, three reasons recur. First, companies state that the necessary data was not available when the report had to be filed – an issue that is being exaggerated by Spain’s six-month deadline, which may not fit neatly with existing financial reporting and CbCR processes.
Second, subsidiaries of non-EU-headquartered groups say that their ultimate parent did not provide the information needed to produce a fuller report.
Third, some businesses invoke commercial confidentiality concerns under the ‘safeguard clause’ permitted by many EU Member States.
These explanations provide useful context, but they do not remove the underlying transparency gap.
Wide differences by country of ultimate incorporation
Our latest analysis continues to reveal marked national differences. The frequency of good application is substantially above average among MNEs headquartered in Spain, at 89%, and Japan, at 69%. It is below average among those headquartered in the United States, at 37%, and Switzerland, at 38%.
The picture for UK-linked companies is more nuanced. MNEs ultimately incorporated on the UK mainland apply the requirements well more often than average, at 60%. By contrast, companies whose ultimate parent is incorporated in a UK overseas territory, such as the Cayman Islands, or a Crown dependency, such as Jersey, remain among the weakest performers: only 32% are rated as applying the requirements well.
Few companies improve after their first attempt
With reporting cycles advancing, we can increasingly assess what companies do next. We have now analysed 91 subsequent reports from the same MNEs, including both filings for a later financial year and revised reports replacing an earlier filing for the same period. Yet only a handful show a tendency to improve. This suggests that weak first reports cannot simply be dismissed as teething problems that are likely to be resolved in future reporting cycles.
Freely accessible registers can make transparency work better
A small number of EU Member States are also showing how accessibility can be improved. Instead of relying solely on reports being placed on individual company websites, they provide freely accessible registers where filings can be lodged and found centrally. Ireland’s dedicated document library is the clearest example. This approach makes reports easier to locate, compare and scrutinise, and reduces the risk that disclosures technically exist but are difficult for stakeholders to find.
The EU pCbCR Directive is beginning to deliver a major expansion in corporate tax information. Investors, civil society, policymakers and communities can use these disclosures to form a more rounded view of multinational tax conduct. However, our rating of a substantial minority of reports as poor highlights that publication alone is not enough: the quality, completeness and accessibility of the data also matter.
For the full analysis, company ratings and latest data, visit the Fair Tax Foundation’s pCbCR Resource Hub.
To learn more about public Country-by-Country Reporting, read our guide: Public Country-by-Country Reporting: Why and how multinationals should lift the lid on their taxes
For access to our detailed database of MNEs and their public reports, please contact us directly.
Email: [email protected]
Telephone: +44 (0)161 250 6595
