Commission Implementing Regulation (EU) 2024/2952 of 29 November 2024 laying down a common template and electronic reporting formats for the application of Directive 2013/34/EU of the European Parliament and of the Council as regards the information to be presented in reports on income tax information

• CELEX: Implementing Regulation (EU) 2024/2952
• Articles: 10

Article 1 Subject matter and scope

This Regulation lays down the common template and electronic reporting formats, referred to in Article 48c(4) of Directive 2013/34/EU, to be used for the presentation of the report on income tax information.

Article 2 Definitions

For the purposes of this Regulation, the following definitions shall apply:

(1)

‘report on income tax information’ means a report drawn up, published and made accessible pursuant to Article 48b(1) of Directive 2013/34/EU, and including the information referred to in Article 48c, paragraphs (2) and (3);

(2)

‘core taxonomy’ means the combined set of the taxonomy elements set out in table 2 of Annex IV and the following collection of links:

(a)

presentation linkbase, which groups the taxonomy elements;

(b)

calculation linkbase, which expresses arithmetic relationships between taxonomy elements;

(c)

label linkbase, which describes the meaning of each taxonomy element;

(d)

definition linkbase, which reflects dimensional relationships of the core taxonomy elements;

(3)

‘XHTML format’ means a standard type of format in Hyper Text Markup Language (HTML) complying with the Extensible Hyper Text Markup Language (XHTML);

(4)

‘Inline XBRL’ means a specification of the eXtensible Business Reporting Language (XBRL) standard developed by XBRL International.

Article 3 Common template

Undertakings shall ensure that the visual presentation and content of the report on income tax information comply with the specifications provided for in Annex I.

Article 4 Electronic reporting format and rules on mark-ups

1.   When drawing up the report on income tax information, undertakings shall ensure the following:

(a)

the use of the XHTML format and the embedding of markups using the Inline XBRL specifications, in accordance with the applicable XBRL specifications set out in Annex II;

(b)

the mark-up of disclosures of information using the core taxonomy with the elements listed in Table 2 of Annex IV, in accordance with the marking up and filing requirements set out in Annex III.

2.   Without prejudice to the obligations in paragraph 1, point (b), of this Article, undertakings may mark up disclosures of information using the core taxonomy with the elements listed in Table 3 of Annex IV.

Article 5 Transitional provisions

Undertakings shall apply this Regulation to reports on income tax information for the financial years starting on or after 1 January 2025.

Article 6 Entry into force

This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union .

Schedules & Appendices

ANNEX I Common template for the report on income tax information

ANNEX I

Common template for the report on income tax information

REPORT ON CORPORATE INCOME TAX INFORMATION

in compliance with chapter 10a of Directive 2013/34/EU

(‘country-by-country reporting’)

General reporting instructions

Information required by Article 48c of Directive 2013/34/EU shall be visually presented in accordance with the specifications provided in this template. Additional information may be disclosed in the report, whether in the form of text, images or other means.

Section 1

General information

Name of the ultimate parent of the group / of the standalone undertaking

...

Country where the ultimate parent has its registered office

...

Financial Year – start date

...

Financial Year – end date

...

Reporting currency

...

Is the information in the report based on reporting instructions used for tax purposes, pursuant to Section III, Parts B and C, of Annex III to Directive 2011/16/EU (yes/no)?

...

Specific reporting instructions for Section 1

The name of the ultimate parent of the group / of the standalone undertaking shall correspond to the name provided in the statutes or instruments of incorporation of the undertaking to which the report on income tax information relates.

Whether the reporting instructions pursuant to Section III, Parts B and C, of Annex III to Council Directive 2011/16/EU have been used as a basis to draw up the report, pursuant to Article 48c(3) of Directive 2013/34/EU, this shall be indicated. In the template this would be done by stating ‘yes’ or ‘no’ in the appropriate box. In the case where a reporting undertaking chooses to apply those instructions, these shall apply consistently to Section 2 and 3. These reporting instructions take into account the OECD standards in relation to action 13 of its Action Plan on Base Erosion and Profit Shifting (BEPS).

Section 2

Overview of information on a country-by-country basis

Tax jurisdiction

Country code

Revenues

Profit (loss) before income tax

Income tax paid – on cash basis

Income tax accrued – current year

Accumulated earnings

Number of employees

1.

Full name of Member State or tax jurisdiction A

2.

Full name of Member State or tax jurisdiction B

3.

...

All other tax jurisdictions (aggregated basis)

-

Specific reporting instructions for Section 2

In the table, a given line shall correspond to a given Member State or to a given tax jurisdiction, including a country in the European Economic Area other than a Member State of the European Union, as mandated by the applicable national law.

As many additional columns may be added as necessary on the right-hand side of the table, for any additional information a reporting undertaking may disclose.

The information required by the third subparagraph of Article 48c(5) of Directive 2013/34/EU shall be presented in the line with the heading ‘All other tax jurisdictions (aggregated basis)’. The information shall be disclosed as a zero figure or ‘nil’ if the jurisdictions disclosed line by line cover all the activities of the reporting standalone undertaking or ultimate parent undertaking.

Amounts shall be reported down to the unit with no scaling applied, and with an accuracy deemed appropriate by the reporting undertaking. For example, revenues of EUR 1 234 567,89 would be reported as EUR 1 234 568 (down to the unit, no scaling). With an accuracy to the nearest EUR 1 000, the amount would be reported as EUR 1 235 000.

Case where the report is not based on the reporting instructions for tax purposes pursuant to Section III, Parts B and C, of Annex III to Directive 2011/16/EU:

—

Revenues in a jurisdiction shall be reported with positive amounts. Conversely, where there are overall negative revenues in that jurisdiction, these shall be reported with negative amounts.

—

Profit before income tax in a jurisdiction shall be reported with positive amounts. Conversely, where there are overall losses before tax in that jurisdiction, these shall be reported with negative amounts.

—

Income tax paid on cash basis in a jurisdiction shall be reported with positive amounts. Conversely, where there is an overall net refund of income tax in that jurisdiction, or where refunds of income tax exceeded payments of income tax in the same financial year, income tax paid (on cash basis) shall be reported with negative amounts.

—

Income tax accrued – during the course of the current year in a jurisdiction shall be reported with positive amounts where this corresponds to an overall accrued tax expense in that jurisdiction. Conversely, where there is an overall accrued tax credit in that jurisdiction, the amounts shall be reported with negative amounts.

—

Accumulated earnings in a jurisdiction shall be reported with positive amounts where there are net accumulated profits overall in that jurisdiction. Conversely, where there are overall net accumulated losses in a jurisdiction, accumulated earnings shall be reported with negative amounts.

—

The number of employees in a jurisdiction shall be reported with positive amounts. Decimals may be shown as deemed appropriate by the reporting standalone undertaking or ultimate parent undertaking.

Case where the report is based on the reporting instructions for tax purposes pursuant to Section III, Parts B and C, of Annex III to Council Directive 2011/16/EU:

—

Information relating to undertakings deemed not to be resident in any tax jurisdiction for tax purposes shall be included in the line ‘All other tax jurisdictions (aggregated basis)’.

Section 3

List of subsidiaries and activities

Member State or tax jurisdiction

Country code

Name of each subsidiary undertaking in the Member State or tax jurisdiction

Brief description of the nature of activities in the Member State or tax jurisdiction

1.

Full name of Member State or tax jurisdiction A

Subsidiary a

Subsidiary b

Subsidiary c

....

2.

Full name of Member State or tax jurisdiction B

Subsidiary d

Subsidiary e

Subsidiary f

....

3.

...

....

....

Specific reporting instructions for Section 3

The lines in the table shall correspond to the lines disclosed in Section 2 per Member State or tax jurisdictions. However, the table for Section 3 need not include the line ‘All other tax jurisdictions (aggregated basis)’.

The name of the subsidiary undertakings in the Member State or tax jurisdiction shall be disclosed for each subsidiary undertaking consolidated in the financial statements of the ultimate parent undertaking in respect of the relevant financial year, and presented in the line corresponding to the Member State or tax jurisdictions in which that subsidiary is established. Establishments, fixed places of business or permanent business activities other than those operating via a subsidiary undertaking need not be disclosed.

Case where the report is not based on the reporting instructions for tax purposes pursuant to Section III, Parts B and C, of Annex III to Council Directive 2011/16/EU:

—

The ‘Brief description of the nature of activities in the Member State or tax jurisdiction’ shall be drawn up on the basis of Annex I of Regulation (EC) No 1893/2006 of the European Parliament and of the Council  ( 1 ) establishing the statistical classification of economic activities (NACE), taking account of the activities of the group or standalone company in the country as a whole. For example, taking all the activities in a given country into account, where these cover section C and G of Annex I of Regulation (EC) No 1893/2006, the corresponding text would be: ‘manufacturing / wholesale and retail trade; repair of motor vehicles and motorcycles’.

Case where the report is based on the reporting instructions for tax purposes pursuant to Section III, Parts B and C, of Annex III to Council Directive 2011/16/EU:

—

The information required by the line entitled ‘Brief description of the nature of activities in the Member State or tax jurisdiction’ shall be disclosed on the basis of the following list of main business activities, taking into account all the activities in a given country:

—

Research and Development

—

Holding or Managing Intellectual Property

—

Purchasing or Procurement

—

Manufacturing or Production

—

Sales, Marketing or Distribution

—

Administrative, Management or Support Services

—

Provision of Services to Unrelated Parties

—

Internal Group Finance

—

Regulated Financial Services

—

Insurance

—

Holding Shares or Other Equity instruments

—

Dormant

—

Other

—

For instance: ‘Manufacturing or Production / Sales, Marketing or Distribution’. In the case where the activities are reported as ‘Other’, no further description is required.

Section 4

Omitted information

Information omitted (if any) for this financial year:

.....

Information omitted in previous financial years, which is disclosed in this financial year (if any):

.....

Specific reporting instructions for Section 4

Applicable national law pursuant to Article 48c(6) of Directive 2013/34/EU may provide for the ability to temporarily omit information.

Where information is omitted in either table laid down in section 2 or 3, this shall be disclosed in the first box in Section 4. For each item omitted (if any), the description of such item as well as a duly reasoned explanation regarding the reason for the omission shall be provided in the box.

For information that had been omitted in a previous financial year and which is disclosed in the report on income tax information for the current financial year, the description of each item shall be provided in the second box in Section 4, indicating for each item disclosed the financial year in which the information had been omitted.

Section 5 (non-mandatory)

Explanations for material discrepancies between income tax paid and accrued

Explanations on material discrepancies between amounts of income tax accrued during the relevant financial year and amounts of income tax paid on a cash basis as disclosed in Section 2, where applicable at group level, considering where appropriate corresponding amounts concerning previous financial years:

.....

Specific reporting instructions for Section 5

Unless provided otherwise by the applicable national law, it is left to the discretion of reporting undertakings whether or not to provide such information. Should no such information be disclosed, this section may be omitted. This section is mentioned in this common template by reference to Article 48c(7) of Directive 2013/34/EU.

( 1 )   Regulation (EC) No 1893/2006 of the European Parliament and of the Council of 20 December 2006 establishing the statistical classification of economic activities NACE Revision 2 and amending Council Regulation (EEC) No 3037/90 as well as certain EC Regulations on specific statistical domains ( OJ L 393, 30.12.2006, p. 1 , ELI: http://data.europa.eu/eli/reg/2006/1893/oj ).

ANNEX II Applicable XBRL specifications

ANNEX II

Applicable XBRL specifications

1.

Undertakings shall ensure that the Inline XBRL instance document is valid with respect to the Inline XBRL 1.1 specification and is in conformity with the XBRL Units Registry.

2.

Undertakings shall provide the Inline XBRL instance document as a stand-alone XHTML file. The Inline XBRL instance document can have either a.html or.xhtml extension when submitted.

3.

Undertakings shall ensure that the Inline XBRL instance document respects the marking up and filing requirements set out in Annex III.

The XBRL standards are open and freely licensed by way of the XBRL International License Agreement. The use of XBRL registered trademarks is permitted by XBRL International in accordance with the XBRL International Trademark Policy.

ANNEX III Marking up and filing requirements

ANNEX III

Marking up and filing requirements

1.

When disclosing information on currency, the ISO 4217:2015 Currency codes shall be used  ( 1 ) .

2.

When reporting information on country code, the ISO 3166-1:2020 alpha-2 country codes shall be used  ( 2 ) .

3.

When reporting information on dates, the date component shall follow the ISO 8601-1:2019 date in UTC format YYYY-MM-DD  ( 3 ) .

4.

Undertakings shall identify themselves in the Inline XBRL instance document using XBRL context entity identifiers and schemes. The identifier shall be a string of characters allowing for the unique identification of the reporting undertaking and shall correspond to the name of the ultimate parent or standalone undertaking as disclosed in Annex I, Section 1. By way of derogation to the second sentence of this paragraph, undertakings may substitute the name with either one of the following identifiers:

a)

a European unique identifier (EUID) as referred to in Article 16(1) of Directive (EU) 2017/1132 of the European Parliament and of the Council  ( 4 ) ,

b)

an ISO 17442 compliant legal entity identifier, or

c)

a tax identification number.

5.

Undertakings shall ensure that the Inline XBRL instance document contains data of a single undertaking, so that all entity identifiers in contexts shall have identical content.

6.

When marking up disclosures, undertakings shall use the core taxonomy element with the closest meaning to the meaning of the disclosure being marked up. Where there appears to be a choice of core taxonomy elements, issuers shall select the element with the narrowest meaning and/or scope.

7.

When disclosing numeric facts, undertakings shall use numeric elements listed in the core taxonomy and shall disclose exact values for such numeric facts with no scaling. Undertakings may apply any accuracy that they deem appropriate.

8.

When marking up disclosures, undertakings shall use non-numeric elements listed in the core taxonomy in a way that these mark up all disclosures that match the meaning of the respective element. Undertakings shall not apply the markups only partially or selectively.

9.

Undertakings shall ensure that the Inline XBRL instance document does not contain executable code.

( 1 )

https://www.iso.org/standard/64758.html .

( 2 )

https://www.iso.org/standard/72482.html .

( 3 )

https://www.iso.org/obp/ui/en/#iso:std:iso:8601:-1:ed-1:v1:en .

( 4 )   Directive (EU) 2017/1132 of the European Parliament and of the Council of 14 June 2017 relating to certain aspects of company law (codification) ( OJ L 169, 30.6.2017, p. 46 , ELI: http://data.europa.eu/eli/dir/2017/1132/oj ).

ANNEX IV Taxonomy elements

ANNEX IV

Taxonomy elements

Table 1

Legend for the element type and attributes

Data / Attribute type

Definition

abstract

denotes a grouping element or a header

date

denotes that the element type is a date; dates are non-numeric line items

instant or duration

denotes that a monetary value or a numeric line item represents a stock (if instant) or a flow (if duration)

line items

denote elements in rows of a table

table

denotes the beginning of a structure represented by a table

text

denotes that the element type is text (a sequence of alphanumeric characters); it is used to mark up short pieces of narrative information; text elements are non-numeric line items

text block

denotes that the element type is a block of text; it is used to mark up larger pieces of information; text blocks are non-numeric line items

true/false

denotes that element type is a true or false statement; true/false statements are non-numeric line items

typed axis

denotes a dimensional property in a tabular structure, where the format for such dimensional property is defined in the taxonomy and the value of such dimensional property is provided by an undertaking in the report

X

denotes that the element type is monetary (a number in a declared currency); these elements are numeric line items

X.XX

denotes that element type is a decimalised value; these elements are numeric line items

Table 2

List of taxonomy elements

Element name

Element type and attributes

Label type

Label content

References

AccumulatedEarnings

X instant

Label

Accumulated earnings

Article 48c(2)(h), Directive 2013/34/EU

AccumulatedEarningsOtherTaxJurisdictions

X instant

Label

Accumulated earnings, other tax jurisdictions

Article 48c(5), Directive 2013/34/EU

ApplicationOfOptionToReportInAccordanceWithTaxationReportingInstructions

True/False

Label

Application of option to report in accordance with taxation reporting instructions

Article 48c(3), Directive 2013/34/EU

VerboseLabel

Option to use reporting instructions referred to in Section III, Parts B and C, of Annex III to Council Directive 2011/16/EU is applied

CountryCodeOfMemberStateOrTaxJurisdiction

Text

Label

Country code of Member State or tax jurisdiction

Article 48c(5), Directive 2013/34/EU

CountryOfRegisteredOfficeOfUltimateParentUndertaking

Text

Label

Country of registered office of ultimate parent undertaking

VerboseLabel

Country where ultimate parent has its registered office

DateOfEndOfFinancialYear

Date

Label

Date of end of financial year

Article 48c(2)(a), Directive 2013/34/EU

DateOfStartOfFinancialYear

Date

Label

Date of start of financial year

Article 48c(2)(a), Directive 2013/34/EU

DescriptionOfNatureOfActivitiesOfSubsidiaryUndertakingsInMemberStateOrTaxJurisdictionExplanatory

Text block

Label

Description of nature of activities of subsidiary undertakings in Member State or tax jurisdiction [text block]

Article 48c(2)(b), Directive 2013/34/EU

VerboseLabel

Brief description per country of nature of activities in Member State or tax jurisdiction

DisclosureOfInformationOmittedForPreviousFinancialYearsExplanatory

Text block

Label

Disclosure of information omitted for previous financial years [text block]

Article 48c(6), Directive 2013/34/EU

DisclosureOfNamesOfSubsidiaryUndertakingsConsolidatedInFinancialStatementsOfUltimateParentUndertakingExplanatory

Text block

Label

Disclosure of names of subsidiary undertakings consolidated in financial statements of ultimate parent undertaking [text block]

Article 48c(2)(a), Directive 2013/34/EU

TerseLabel

Name of subsidiary undertakings consolidated in financial statements of ultimate parent undertaking

DisclosureOfTypeOfInformationOmittedExplanatory

Text block

Label

Disclosure of type of information omitted [text block]

Article 48c(6), Directive 2013/34/EU

TerseLabel

Information omitted

DisclosureOfTypeOfInformationOmittedOtherTaxJurisdictionsExplanatory

Text block

Label

Disclosure of type of information omitted, other tax jurisdictions [text block]

Article 48c(6), Directive 2013/34/EU

TerseLabel

Information omitted, other tax jurisdictions

ExplanationOfAnyMaterialDiscrepanciesBetweenIncomeTaxPaidAndAccruedAbstract

Label

Explanation of any material discrepancies between income tax paid and accrued [abstract]

ExplanationOfAnyMaterialDiscrepanciesBetweenIncomeTaxPaidAndAccruedExplanatory

Text block

Label

Explanation of any material discrepancies between income tax paid and accrued [text block]

Article 48c(7), Directive 2013/34/EU

ExplanationOfReasonForOmissionOfInformationExplanatory

Text block

Label

Explanation of reason for omission of information [text block]

Article 48c(6), Directive 2013/34/EU

GeneralInformationAbstract

Label

General information [abstract]

IncomeTaxAccrued

X duration

Label

Income tax accrued

Article 48c(2)(f), Directive 2013/34/EU

VerboseLabel

Income tax accrued – current year

IncomeTaxAccruedOtherTaxJurisdictions

X duration

Label

Income tax accrued, other tax jurisdictions

Article 48c(5), Directive 2013/34/EU

VerboseLabel

Income tax accrued – current year, other tax jurisdictions

IncomeTaxPaidOnCashBasis

X duration

Label

Income tax paid (on cash basis)

Article 48c(2)(g), Directive 2013/34/EU

IncomeTaxPaidOnCashBasisOtherTaxJurisdictions

X duration

Label

Income tax paid (on cash basis), other tax jurisdictions

Article 48c(5), Directive 2013/34/EU

ListOfSubsidiariesAndActivitiesAbstract

Label

List of subsidiaries and activities [abstract]

ListOfSubsidiariesAndActivitiesLineItems

Label

List of subsidiaries and activities [line items]

ListOfSubsidiariesAndActivitiesTable

Label

List of subsidiaries and activities [table]

NameOfMemberStateOrTaxJurisdictionTypedAxis

Typed axis

Label

Name of Member State or tax jurisdiction [typed axis]

Article 48c(5), Directive 2013/34/EU

NameOfSingleSubsidiaryPublishingNonEUUndertakingReport

Text

Label

Name and registered office of a single subsidiary undertaking which has published the report on income tax information of an undertaking that is not governed by the law of a Member State

Article 48b(6)(b), Directive 2013/34/EU

NameOfSingleBranchPublishingNonEUUndertakingReport

Text

Label

Name and address of a single branch which has published the report on income tax information of an undertaking that is not governed by the law of a Member State

Article 48b(6)(b), Directive 2013/34/EU

NameOfUltimateParentOfGroupOfStandaloneCompany

Text

Label

Name of ultimate parent of group / of standalone company

Article 48c(2)(a), Directive 2013/34/EU

VerboseLabel

Name of ultimate parent of group / of standalone company (complete as per statutes or business register)

NumberOfEmployees

X.XX instant

Label

Number of employees

Article 48c(2)(c), Directive 2013/34/EU

NumberOfEmployeesOtherTaxJurisdictions

X.XX instant

Label

Number of employees, other tax jurisdictions

Article 48c(5), Directive 2013/34/EU

OmittedInformationAbstract

Label

Omitted information [abstract]

OverviewOfAllocationOfElementsOnCountrybycountryBasisAbstract

Label

Overview of allocation of elements on country-by-country basis [abstract]

OverviewOfAllocationOfElementsOnCountrybycountryBasisAllOtherTaxJurisdictionsAggregatedBasisAbstract

Label

Overview of allocation of elements on country-by-country basis, all other tax jurisdictions (aggregated basis) [abstract]

OverviewOfAllocationOfElementsOnCountrybycountryBasisMemberStateOrTaxJurisdictionAbstract

Label

Overview of allocation of elements on country-by-country basis, Member State or tax jurisdiction [abstract]

OverviewOfAllocationOfElementsOnCountrybycountryBasisMemberStateOrTaxJurisdictionLineItems

Label

Overview of allocation of elements on country-by-country basis, Member State or tax jurisdiction [line items]

OverviewOfAllocationOfElementsOnCountrybycountryBasisMemberStateOrTaxJurisdictionTable

Label

Overview of allocation of elements on country-by-country basis, Member State or tax jurisdiction [table]

ProfitLossBeforeTax

X duration

Label

Profit (loss) before tax

Article 48c(2)(e), Directive 2013/34/EU

VerboseLabel

Profit (loss) before income tax

ProfitLossBeforeTaxOtherTaxJurisdictions

X duration

Label

Profit (loss) before tax, other tax jurisdictions

Article 48c(5), Directive 2013/34/EU

VerboseLabel

Profit (loss) before income tax, other tax jurisdictions

ReportingCurrency

Text

Label

Reporting currency

Article 48c(2)(a), and Article 48(c)8, Directive 2013/34/EU

Revenues

X duration

Label

Revenue

Article 48c(2)(d), Directive 2013/34/EU

TerseLabel

Revenues

RevenuesOtherTaxJurisdictions

X duration

Label

Revenue, other tax jurisdictions

Article 48c(5), Directive 2013/34/EU

TerseLabel

Revenues, other tax jurisdictions

Table 3

List of additional taxonomy elements

Element name

Element type and attributes

Label type

Label content

References

Assets

X instant

Label

Tangible assets other than cash and cash equivalents

AssetsOtherTaxJurisdictions

X instant

Label

Tangible assets other than cash and cash equivalents, other tax jurisdictions

Capital

X instant

Label

Stated capital

CapitalOtherTaxJurisdictions

X instant

Label

Stated capital, other tax jurisdictions

LanguageOfReport

Text

Label

Language of report

PublicSubsidiesReceived

X duration

Label

Public subsidies received

PublicSubsidiesReceivedOtherTaxJurisdictions

X duration

Label

Public subsidies received, other tax jurisdictions

RevenuesRelated

X duration

Label

Revenues from transactions with related parties

RevenuesRelatedOtherTaxJurisdictions

X duration

Label

Revenues from transactions with related parties, other tax jurisdictions

RevenuesUnrelated

X duration

Label

Revenues from transactions with non-related parties

RevenuesUnrelatedOtherTaxJurisdictions

X duration

Label

Revenues from transactions with non-related parties, other tax jurisdictions