EU Public CbCR (Directive 2021/2101): What Gets Published

The EU Public CbCR Directive (Directive (EU) 2021/2101) is the regime that makes the CbCR public: the large groups in scope must publish their CbCR data — the jurisdictional profile of the group’s income, profit, tax, employees and assets — on their website, in a machine-readable format, as part of the annual financial reporting cycle. It is the CbCR’s transparency overlay: the same data the CbCR filing carries (and the Pillar Two computation runs on) — but published, not merely exchanged between the authorities. For the group with the EU parent (or the EU ultimate parent’s group), the public CbCR is a standing disclosure obligation, and the data it publishes is the data the group’s transfer pricing position is built on — the publication is the position, in public.

The scope

Element	The content
The groups in scope	The consolidated groups meeting the Directive’s size test — the large groups (the average headcount and the balance-sheet/turnover thresholds, per the Directive’s scope — the large enterprise groups, the test applied over the preceding financial years per the Directive’s criteria) — the scope wider than the CbCR’s €750 mn in some cases, narrower in others, per the Directive’s own thresholds (the headcount-plus-balance-sheet/turnover test)
The entities obliged	The ultimate parent entity established in the EU (or the parent entity in the EU, where the group’s ultimate parent is outside the EU and the EU parent meets the conditions — the EU entity that prepares the consolidated accounts, the one that publishes)
The publication	The CbCR data published on the entity’s website, for a specified retention period (the Directive’s publication period — the current and the preceding years’ data, publicly available), in the machine-readable format (the iXBRL-tagged format, per the technical standard the European Commission develops under the Directive)

The scope’s reading: the group with the EU parent (or the EU consolidation parent) publishes — the Indian group with the EU ultimate parent (or the EU parent that consolidates the group) is the publication obligation’s case, and the data published is the group’s CbCR profile, publicly.

What gets published

The public CbCR carries three data sets, per the Directive:

Data set	The content
The group’s CbCR data	The jurisdictional rows — per jurisdiction: the revenue (the external and the related-party), the profit before tax, the income tax paid, the income tax currently due, the number of employees, the tangible assets — the [CbCR’s seven
items](/docs/documentation/cbcr-guide), the group’s jurisdictional profile, published
The parent information	The ultimate parent’s identity, the group’s structure information (the parent entity, the group’s main activities, the consolidated group’s headcount and the total revenue — the group-level profile)
The country-by-country data	The jurisdictional breakdown, the core of the publication — the group’s income, profit, tax, employees and assets, by country, the table that is the CbCR’s substance, public

The publication’s character: the group’s global tax profile, in public — the jurisdictional profit allocation, the jurisdictional tax, the effective rates (computable from the published profit and tax), the headcount, the assets — the data the risk assessment runs on (the CbCR flag analysis) now available to everyone: the competent authorities (the exchange already carries it), the investors, the media, the NGOs, the competitors. The group’s transfer pricing position — the profit’s allocation across the jurisdictions — is the publication’s substance, and it is public.

The machine-readable format

The Directive’s publication requirement is the machine-readable format — the iXBRL-tagged data (the inline XBRL, the tagged format the financial statements carry), per the technical standard the European Commission develops (the delegated act / the implementing standard, the iXBRL tag set for the CbCR data). The format’s purpose: the data extractable and aggregable — the machine-readable publication is the data the researchers, the authorities, the analysts aggregate across groups and across years — the group’s CbCR profile in the machine-readable form, as the dataset, not the PDF.

The format’s consequence for the group: the published data is the data as structured (the tagged fields, the jurisdictional rows, the standard format) — the data quality standard is the data as published, and the publication error (the wrong jurisdictional row, the wrong tax figure, the missing jurisdiction) is the public error, in the machine-readable form, correctable only by the re-publication (the amended publication, per the Directive’s correction mechanics).

What it means for the group’s TP posture

The public CbCR changes the CbCR’s role from the exchange instrument (the authorities’ data) to the public record (the group’s tax profile, public) — and the consequences:

Consequence	The content
The TP position is public	The jurisdictional profit allocation (the intercompany pricing’s output) is the published table — the group’s transfer pricing position, the profit’s location across the jurisdictions, is the public data. The pricing that was the file’s substance is now the website’s table
The ETRs are computable, publicly	The jurisdictional ETRs (the tax over the profit, per the published rows) are computable by anyone — the [CbCR flag
analysis](/docs/documentation/cbcr-guide) runs on public data, and the group’s low-ETR jurisdictions (the IP holding, the 0/9% jurisdiction, the loss jurisdiction) are the public flags — the flags the Pillar Two computation runs on, publicly visible
The consistency is public	The published CbCR vs the Local Files (the entity-level data), vs the Master File (the segment data), vs the statutory accounts — the [three-tier
reconciliation](/docs/documentation/tp-documentation-guide) is the consistency the publication must hold, and the inconsistency is the public inconsistency (the published row that does not match the accounts, the entity data that does not sum to the jurisdiction row)
The Pillar Two interaction	The public CbCR data is the [Pillar Two computation’s
input set](/docs/pillar-two/cbcr-and-pillar-two) — and for the in-scope group, the computation’s inputs are public. The top-up tax’s base (the ACI, the covered taxes, the SBIE) is built on the public data, and the group’s Pillar Two position (the ETRs, the top-ups) is the public-data computation
The stakeholder read	The investors (the tax risk, the jurisdictional profile), the media/NGOs (the low-ETR jurisdictions, the profit location), the competitors (the group’s structure, the margins) — the publication’s audience is the group’s stakeholder map, and the data is the group’s tax posture in their hands

The working discipline follows: the data published is the data the group stands behind — the CbCR rows (the profit, the tax, the employees, the assets) are the rows the group’s transfer pricing position supports, the reconciliation holds (the three tiers, the accounts), and the low-ETR jurisdictions (the flags) are the jurisdictions the group can explain (the substance — the SBIE’s payroll and assets — the ETR and SBIE position, the reason the ETR is what it is). The publication is not the problem — the publication of a position the group cannot explain is.

The group’s working position

1. The scope check — the group’s ultimate parent (the EU-established? the EU consolidation parent?) — the publication obligation’s case, per the Directive’s scope, confirmed against the current implementing standard.
2. The data, publication-grade — the CbCR rows as the published data: the quality standard (the CbCR data quality) at the publication grade — the rows that reconcile to the accounts, the tiers, the filings, and that the group stands behind publicly.
3. The format — the iXBRL-tagged publication, per the technical standard — the machine-readable data, the tagged fields, the jurisdictional rows, the format the standard requires.
4. The consistency, public — the three-tier reconciliation (the CbCR to the accounts, the Master File, the Local Files) documented and holding — the consistency that is the public record’s integrity.
5. The flags, explained — the low-ETR jurisdictions (the published flags) with the substance story (the SBIE’s payroll and assets, the reason the ETR is the ETR) — the ETR and SBIE position, the explanation the publication invites.

See also

• The CbCR guide — the filing standard
• CbCR and Pillar Two — the data backbone
• ETR and SBIE — the substance story
• Pillar Two for TP teams — the data checklist