Country by Country Reporting Netherlands is an important compliance topic for large multinational enterprise groups with a Dutch entity. Country-by-Country Reporting, also known as CbCR or CbC reporting, requires qualifying multinational groups to report key financial, tax and operational information for each country in which they operate.
For international groups with a Dutch BV, branch or holding company, Country-by-Country Reporting Netherlands can create both reporting and notification obligations. It is important to understand whether a Dutch CbC notification is required, who files the main CbC report and how the CbCR data connects with Dutch tax compliance, transfer pricing documentation and financial reporting.
Country-by-Country Reporting Netherlands: quick answer
Country-by-Country Reporting is a global tax transparency framework for large multinational groups. It requires qualifying groups to report revenue, profit or loss before tax, income tax paid, income tax accrued, employees, tangible assets, stated capital, accumulated earnings and business activities for each country in which they operate.
CbCR was introduced under OECD/G20 BEPS Action 13. Its purpose is to help tax authorities assess whether profits are taxed in the jurisdictions where real economic activity takes place.
In the Netherlands, Country-by-Country Reporting generally applies to multinational groups with consolidated group revenue of at least €750 million in the immediately preceding financial year.
Country-by-Country Reporting Netherlands is especially relevant for international groups that have a Dutch subsidiary, Dutch branch or Dutch holding company. Even when the ultimate parent company files the main CbC report outside the Netherlands, the Dutch entity may still have a local CbC notification obligation.
In this article
- What is Country-by-Country Reporting?
- Who must report under CbCR?
- What is the CbCR filing deadline?
- Master File, Local File and CbC Report
- What information is included in a CbC report?
- OECD CbCR vs EU Public CbCR
- Why CbCR matters for Pillar 2
- Common CbCR risks and blind spots
- How Oakhill can help
- Frequently asked questions
What is Country-by-Country Reporting?
Country-by-Country Reporting is a standardized international tax reporting obligation for large multinational enterprise groups. It requires an overview of key financial, tax and operational metrics per tax jurisdiction.
The framework was introduced under OECD/G20 BEPS Action 13 . BEPS stands for Base Erosion and Profit Shifting. The goal is to improve tax transparency and help tax authorities identify potential transfer pricing and profit allocation risks.
A CbC report does not replace the corporate income tax return, statutory financial statements or transfer pricing documentation. Instead, it gives tax authorities a high-level overview of how a group’s revenue, profits, taxes, employees and assets are allocated across countries.
Country-by-Country Reporting Netherlands: who must report?
Country-by-Country Reporting generally applies to multinational enterprise groups with annual consolidated group revenue of at least €750 million in the immediately preceding fiscal year.
The Dutch Tax Authorities state that Country-by-Country reporting applies to multinational enterprises with revenue from €750 million and consists of three standardized documentation obligations: the country report, the group file and the local file.
Which entity files the CbC report?
The CbC report is usually filed by one of the following entities:
- the ultimate parent entity;
- a surrogate parent entity;
- another appointed reporting entity, depending on the group structure and local rules.
Does a Dutch entity always need to file the full CbC report?
No. A Dutch group company may not be the entity that files the full CbC report. However, a Dutch constituent entity may still need to file a CbC notification in the Netherlands. This notification tells the Dutch Tax Authorities which group entity will file the main Country-by-Country report.
This distinction is important. Many Dutch entities are not responsible for the full CbC report, but they may still have a Dutch notification obligation under the Country-by-Country Reporting Netherlands rules.
Country-by-Country Reporting Netherlands: filing deadline and notification deadline
The Country-by-Country report must generally be prepared and filed annually within 12 months after the end of the reporting financial year.
For Dutch CbC notifications, the deadline is generally no later than the last day of the reporting year. The Belastingdienst CbC portal FAQ states that, for normal reporting years, the CbC report deadline is 31 December, and for deviating reporting years the deadline is the end of the reporting period plus 12 months.
Example for a calendar-year multinational group
| Requirement | Reporting year | Typical deadline |
|---|---|---|
| CbC notification in the Netherlands | 2026 | 31 December 2026 |
| CbC report filing | 2026 | 31 December 2027 |
For Country-by-Country Reporting Netherlands, the practical deadline risk is often the Dutch notification. A Dutch entity may need to act before the full CbC report is filed by the parent company.
Country-by-Country Reporting Netherlands: CbCR, Master File and Local File
Country-by-Country Reporting is part of the broader transfer pricing documentation framework introduced under OECD BEPS Action 13. This framework consists of three core components.
1. Master File
The Master File provides a high-level overview of the multinational group. It usually includes information about the group’s global business activities, organizational structure, intangibles, financing arrangements and transfer pricing policies.
2. Local File
The Local File provides detailed country-specific transfer pricing documentation. It focuses on the local entity and its material intercompany transactions with other group companies.
3. Country-by-Country Report
The Country-by-Country Report is an aggregate data matrix. It shows financial and operational data per tax jurisdiction, allowing tax authorities to compare where profit is reported, where tax is paid and where people, assets and business activities are located.
Country-by-Country Reporting Netherlands: what information is included?
For every jurisdiction in which the multinational group operates, the final CbC report must include standardized financial and operational data points.
| Financial metrics | Operational indicators |
|---|---|
| Revenues from related and unrelated parties | Number of full-time employees |
| Profit or loss before income tax | Net book value of tangible assets |
| Income tax paid on a cash basis | Main business activities |
| Income tax accrued for the current year | Tax jurisdiction of incorporation |
| Stated capital | Constituent entities per jurisdiction |
| Accumulated earnings or retained earnings | Business activity classification |
These metrics are used by tax authorities to identify potential transfer pricing risks, tax base erosion, profit shifting and mismatches between taxable profits and economic substance.
OECD confidential CbCR vs EU Public CbCR
There are two separate Country-by-Country Reporting tracks that large multinational groups need to understand: standard OECD CbCR and EU Public CbCR.
Standard OECD CbCR: confidential tax authority reporting
Standard OECD Country-by-Country Reporting is submitted to the relevant tax authority. In many cases, this is the tax authority in the country where the ultimate parent entity or surrogate parent entity is established.
This report is not made public. It is exchanged between tax authorities through secure government-to-government exchange mechanisms. Within the European Union, this includes automatic exchange between tax authorities.
EU Public CbCR: public disclosure of tax information
EU Public Country-by-Country Reporting is different. It requires certain large multinational groups to make income tax information publicly available.
The European Commission explains that Public Country-by-Country Reporting is part of company reporting and auditing rules. The Commission also launched a public CbCR project to help companies prepare reports in the common template and iXBRL format, as required by the EU framework.
For many calendar-year corporations, the first EU Public CbCR reports relate to the 2025 financial year and are expected to be published in 2026, depending on the applicable local implementation rules.
Key difference
| Topic | Standard OECD CbCR | EU Public CbCR |
|---|---|---|
| Purpose | Tax authority risk assessment | Public tax transparency |
| Audience | Tax authorities | Public, stakeholders and trade registers |
| Confidentiality | Confidential | Public disclosure |
| Format | Tax authority filing format | Public report, including structured electronic reporting requirements |
Why CbCR matters for Pillar 2
Country-by-Country Reporting is no longer only a transfer pricing compliance exercise. CbCR data is also important for Pillar 2 and the global minimum tax framework.
In particular, CbCR data can be relevant for transitional safe harbour calculations. Poor data quality, inconsistent entity mapping or errors in revenue, profit and tax data may create additional tax risk and could affect whether a group can rely on simplified Pillar 2 calculations.
For this reason, groups should review CbCR data before filing. The report should be aligned with the consolidation, local accounts, corporate income tax positions and transfer pricing documentation.
Common CbCR risks and blind spots for businesses
1. Missing CbC notification in the Netherlands
A Dutch entity may assume that no Dutch action is needed because the ultimate parent company files the CbC report abroad. This assumption can be wrong. A Dutch constituent entity may still need to submit a Dutch CbC notification.
2. Confusion between CbC report filing and CbC notification
Filing the full CbC report and submitting a CbC notification are not the same. The CbC report contains the group-wide data matrix. The CbC notification informs the local tax authority which entity is responsible for filing that report.
3. Poor data quality
CbCR data often comes from multiple sources, including ERP systems, consolidation software, tax schedules and local financial statements. Inconsistent mapping can lead to differences between the CbC report, corporate income tax return, annual accounts and transfer pricing documentation.
4. Pillar 2 safe harbour risk
Incorrect CbCR data may create Pillar 2 risk. If the data is not reliable, the group may lose the benefit of certain simplified calculations and may face additional review work.
5. Public scrutiny under EU Public CbCR
Public CbCR can expose differences between where profits are reported and where employees, assets and business substance are located. Groups should proactively review their tax transparency profile before publication.
How Oakhill helps with Country-by-Country Reporting Netherlands
Oakhill Financial Services helps international groups and Dutch entities with the practical side of Country-by-Country Reporting in the Netherlands.
We support clients with Dutch CbCR notifications, coordination with group tax teams, communication with the Dutch Tax Authorities and alignment with related Dutch compliance work.
Oakhill supports Country-by-Country Reporting Netherlands from a practical Dutch compliance perspective. We help international groups determine whether a Dutch notification is required, coordinate with the group tax department and connect the CbCR process with Dutch bookkeeping, annual accounts and tax compliance.
Our CbCR support can include:
- assessing whether a Dutch CbC notification is required;
- identifying the relevant reporting entity within the group;
- preparing and coordinating the Dutch CbCR notification;
- liaising with the Dutch Tax Authorities where needed;
- coordinating with the ultimate parent entity or group tax department;
- reviewing Dutch entity data for CbCR purposes;
- aligning CbCR data with Dutch annual accounts and corporate income tax filings;
- supporting related Dutch tax compliance, bookkeeping and financial reporting work.
For international groups, Oakhill can act as a practical Dutch point of contact. This is especially useful when the group tax team is based outside the Netherlands and needs local support for Dutch compliance deadlines.
Need help with CbCR in the Netherlands?
If your multinational group has a Dutch entity, Oakhill can help determine whether a CbC notification is required and coordinate the Dutch compliance process.
Contact Oakhill Financial Services
Related Dutch compliance and reporting services
Country-by-Country Reporting is often connected to broader Dutch finance and tax compliance. Oakhill can support your Dutch entity through multiple service lines:
- Dutch bookkeeping and financial administration
- Country-by-Country Reporting and Dutch compliance support
Oakhill can also support with Dutch financial reporting, corporate income tax coordination, management reporting and CFO-level guidance for international groups operating in the Netherlands.
Why work with Oakhill?
Oakhill combines financial reporting, Dutch tax compliance, bookkeeping and CFO-level support. This means we do not look at CbCR in isolation. We understand how Country-by-Country Reporting connects with corporate income tax, annual accounts, transfer pricing documentation and management reporting.
This makes our support especially relevant for international groups with a Dutch BV, branch or holding company that need a reliable local finance and compliance partner.
Frequently asked questions about Country-by-Country Reporting Netherlands
What is Country-by-Country Reporting?
Country-by-Country Reporting is a tax transparency requirement for large multinational groups. It requires them to report revenue, profit or loss before tax, income tax paid, income tax accrued, employees, assets and business activities per country.
How does Country-by-Country Reporting Netherlands work?
Country-by-Country Reporting Netherlands applies to Dutch entities that are part of a qualifying multinational group. The Dutch entity may need to submit a CbC notification to the Dutch Tax Authorities, even if the full CbC report is filed by the ultimate parent entity or another reporting entity outside the Netherlands.
Who must file a CbC report?
CbC reporting generally applies to multinational enterprise groups with consolidated group revenue of at least €750 million in the immediately preceding financial year.
What is a CbC notification?
A CbC notification informs the local tax authority which group entity will file the Country-by-Country report. In the Netherlands, Dutch constituent entities may have a notification obligation even if the main CbC report is filed by a foreign parent company.
What is the CbCR deadline in the Netherlands?
The CbC report must generally be filed within 12 months after the end of the reporting financial year. The Dutch CbC notification must generally be submitted no later than the last day of the reporting year.
What is the difference between OECD CbCR and EU Public CbCR?
OECD CbCR is confidential and exchanged between tax authorities. EU Public CbCR requires certain large groups to publish income tax information publicly.
Can Oakhill help with CbCR?
Yes. Oakhill can help assess whether a Dutch CbCR notification is required, coordinate the notification process, liaise with the Dutch Tax Authorities and support related Dutch tax compliance, annual accounts, bookkeeping and financial reporting.
Need help with Country-by-Country Reporting in the Netherlands?
If your multinational group has a Dutch entity, Oakhill Financial Services can help you determine whether a Country-by-Country Reporting notification is required and coordinate the Dutch compliance process.
Contact Oakhill for practical support with Country-by-Country Reporting Netherlands, Dutch corporate income tax, annual accounts, bookkeeping and financial reporting.