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EU Public CbCR - are you ready for tax transparency in 2026?

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EY Denmark

Multidisciplinary professional services organization.

20 May 2026
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Tax

PCbCR rules apply to MNEs with an EU presence and revenues above EUR 750M over the last two years. Public disclosure begins in 2026.

In brief
  • PCbCR rules apply to MNEs with a presence in the EU and global consolidated revenues exceeding EUR 750M over two years, irrespective of the UPE location.
  • For non-EU headquartered groups, the reporting obligation is triggered where the group has at least one medium-sized or large subsidiary or branch in the EU.
  • In Denmark, the filing deadline is 30 June 2026 for groups with a fiscal year ending on 30 June 2025 and 31 December 2026 for calendar-year groups.

What is PCbCR?

Public Country-by-Country report (PCbCR) is a mandatory, public disclosure of the country-by-country information, introduced at EU level through Directive (EU) 2021/2101.

The PCbCR report includes aggregated data on the global allocation of income, profit, income taxes paid and economic activity for all tax jurisdictions in which a multinational group operates. The report must be made publicly available through the relevant national business registers and on the company’s website.

In Denmark, the PCbCR Directive was implemented in April 2023 through amendments to the Danish Financial Statements Act (Årsregnskabsloven, as amended by Act No. 426 of 18 April 2023).

Who is subject to PCbCR in Denmark?

PCbCR applies to multinational groups and standalone entities that are present in the EU and whose consolidated revenue exceeds EUR 750 million in each of the last two consecutive financial years. For multinational groups with a Danish ultimate parent entity, the preparation, submission and publication of the PCbCR report is mandatory.

For groups with a non-Danish ultimate parent entity, whether a Danish entity (a subsidiary or branch) is required to prepare and/or submit the PCbCR report must be assessed on a case-by-case basis. In many cases, Danish entities may still be required to file the report with the Danish Business Authority (Erhvervsstyrelsen), even where another group entity within the EU has already prepared and published the report.

The filing obligation is assessed at entity level, meaning that multiple Danish entities within the same group may be subject to separate filing requirements.

It is worth noting that, where the financial statements are audited, the auditor must state whether the undertaking was subject to PCbCR and, if so, whether the report was published accordingly.

How EY can help

What information must be disclosed?

The information to be disclosed under the PCbCR includes data relating to the ultimate parent entity, covering operations in the EU as well as jurisdictions included on the EU list of non-cooperative tax jurisdictions. The required information includes, among others:

  • A brief description of the nature of activities
  • The number of employees on a full-time-equivalent basis
  • A list of all subsidiary entities established in the EU or in listed non-cooperative tax jurisdictions
  • Revenues
  • Profit or loss before income tax
  • Current income tax accrued (calculated income tax payable in each tax jurisdiction for the financial year to which the report relates)
  • Current income tax paid (income tax paid in each tax jurisdiction in the financial year to which the report relates)
  • Accumulated earnings at year-end

Denmark has implemented the safeguard clause, which allows companies to temporarily omit commercially sensitive information, except for information relating to jurisdictions included on the EU list of non‑cooperative tax jurisdictions. Such omissions are not permanent, and any omitted information must be disclosed no later than five years after the date of omission.

 

Where and how must the report be submitted and published?

The PCbCR report must be submitted to the Danish Business Authority (Erhvervsstyrelsen), and Danish covered entities are required to make a reference to the report on their website for a period of at least five years.

 

How can EY assist?

EY supports entities across every aspect of the PCbCR requirements. We help assess whether your Danish operations are in scope and provide end‑to‑end support with preparation, filing, publication, and narrative explanations, ensuring accurate, efficient, and compliant PCbCR reporting. We also assist in leveraging technology solutions to automate data collection, validate CbCR data, reduce manual effort, and streamline the overall reporting process.

 

Contacts

  • Malte Søgaard, Executive Director, International Tax and Transaction Services, tel. +45 2529 3174
  • Pricila Gomes, Tax Consultant, International Tax and Transaction Services, tel. +45 2529 4357
  • Shamdin Abdulla, Tax Consultant, International Tax Advisory, tel. +45 2529 6788

Summary 

PCbCR is the EU Public Country-by-Country report under Directive 2021/2101. It requires large multinational groups (above €750M revenue) to disclose aggregated data on income, profits, taxes, and activities by jurisdiction. In Denmark, it was implemented in 2023 via the Financial Statements Act, with 2025 as the first reporting year and filing deadlines in 2026. Reports must be filed with the Danish Business Authority and published online. Danish entities may have standalone filing obligations, even if the PCbCR is filed elsewhere in the EU.

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EY logo
EY Denmark
Multidisciplinary professional services organization.
Related topics
Tax

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