ICAC clarifies public CbCR for multinational groups

The obligation to disclose public country-by-country reporting (public CbCR), introduced by the Directive (EU) 2021/2101 and implemented in Spain through the Audit Law, requires certain multinational groups to disclose key information on their activities and taxation.

This requirement applies to ultimate parent entities resident in Spain with consolidated revenues of at least €750 million, as well as to Spanish subsidiaries and branches of multinational groups with non-EU parent companies.

The report must include revenues, profits, accrued and paid taxes, and the number of employees by jurisdiction. It must also be published on the corporate website and filed with the Commercial Registry alongside annual accounts.

A key aspect is the public CbCR publication deadline, set at six months after year-end in Spain.

In this context, ICAC Query 5 (BOICAC 144) provides clarification on its practical application.

The ICAC confirms that the obligation lies with the ultimate parent company, meaning that when it is based in another EU country, the applicable framework will be the parent company’s national legislation.

This interpretation allows alignment with the parent company reporting timeline, reducing uncertainty in intra-EU scenarios.

However, differences remain regarding CbCR deadlines in Spain, highlighting the lack of EU regulatory harmonization, which continues to challenge multinational groups operating in Spain.

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