Large multinational corporations will soon face increased scrutiny as a new European Union directive mandates public disclosure of their corporate tax payments. Applicable to companies with annual revenues exceeding €750 million,the directive-stemming from a broader push for tax openness dating back to 2015 [[3]]-aims to curb tax avoidance and foster fairer competition within the bloc. Initial implementation has varied across member states, with Romania and Croatia among the first to begin requiring the reports, and now companies are navigating evolving reporting standards and deadlines, particularly in Spain where a shortened timeframe presents unique compliance challenges.
A new European Union directive is requiring large companies to publicly disclose details of their corporate tax payments, a move aimed at increasing transparency in international finance. The Directive (EU) 2021/2101 impacts businesses with consolidated annual revenues exceeding €750 million (approximately $810 million USD), and is already prompting changes in reporting practices across the continent.
Generally, the reporting requirement applies to entities and groups exceeding the revenue threshold in each of the last two consecutive fiscal years. Beyond groups with parent companies based in Spain, the rule also extends to subsidiaries and branches of groups whose ultimate parent company is not subject to tax law in Spain or another EU member state, though certain conditions apply.
The required report, known as the “Report,” must include a range of financial data, including net turnover, employee numbers, profits or losses before income tax, and the amount of corporate income tax accrued and paid. While non-compliance doesn’t currently carry financial penalties, companies face potential reputational risks. Furthermore, auditors are now required to include a statement in the following year’s audit report confirming timely and accurate compliance with the directive, a requirement currently being finalized by the ICAC, as detailed in the Resolution of October 16, 2025.
The reporting obligation applies to fiscal years beginning on or after June 22, 2024. While the directive set a maximum timeframe, some EU member states have moved to implement the rules earlier. Romania, for example, began requiring the reports for fiscal years starting January 1, 2023, with initial submissions already completed. Croatia followed suit, requiring reports for fiscal years beginning January 1, 2024, with a submission deadline of December 31, 2025.
For many companies – particularly those with fiscal years aligned with the calendar year – the first reporting period is nearing completion. The directive is part of a broader effort to combat tax avoidance and promote fairer competition within the EU.
Two key updates have emerged since initial guidance was released. First, in December 2024, the European Commission published Regulation (EU) 2024/2952, establishing a common template and electronic formats for submitting the required information. Article 5 of the regulation mandates the use of this format for reports relating to fiscal years beginning January 1, 2025, potentially creating uncertainty for companies whose fiscal year began between June 22, 2024, and January 1, 2025, regarding which format to use.
Second, in February 2025, the list of non-cooperative jurisdictions was reviewed and confirmed through the Council Conclusions on the revised EU list of non-cooperative countries and territories for tax purposes. This allows companies to identify jurisdictions requiring individualized reporting. The list includes American Samoa, Anguilla, Fiji, Guam, Palau, Panama, the Russian Federation, Samoa, Trinidad and Tobago, the U.S. Virgin Islands, and Vanuatu, among others.
Spain was among the first EU member states to transpose the directive into national law, doing so through Law 28/2022, second only to Hungary. However, Spain introduced a modification to the directive’s general rules, shortening the approval and publication deadline from a maximum of twelve months after the end of the fiscal year to six months, allowing the report to be filed alongside annual accounts.
This shorter timeframe puts Spanish parent companies, as well as subsidiaries in Spain of non-EU parent companies, at a disadvantage compared to those in other member states, which generally adhere to the twelve-month deadline.
The directive allows subsidiaries to be exempt from the reporting requirement if the ultimate parent company, not subject to the law of an EU member state, has prepared a compatible report and designates a single EU subsidiary or branch to file it with its accounts. However, this solution requires timely publication of the report, both at the parent company level and by the designated EU subsidiary, within a timeframe of twelve months under the directive and in most other EU member states. Spain’s six-month deadline creates a challenge, as it requires parent companies to adapt to a shorter reporting timeline, which is often outside their control.
This discrepancy could result in a group complying with reporting deadlines across Europe, except in Spain, creating an unnecessary compliance issue for Spanish subsidiaries.
For groups with fiscal years aligned with the calendar year, the first report will be for the 2025 fiscal year, and companies should begin preparations in the coming months. For further information, please contact our specialists through the Knowledge and Innovation Area.
