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The introduction of Public Country-by-Country Reporting (“Public CbCR”) in Malta imposes new obligations on multinational groups, representing a significant shift towards enhanced corporate tax transparency across the European Union.
What is Public CbCR?
Public CbCR is an EU transparency measure that requires certain multinational groups to publicly report specified tax and business information for each jurisdiction in which they operate. The information required to be disclosed includes, among other things, revenue, profit or loss, income taxes paid and accrued, employee data and accumulated earnings.
Public CbCR is distinct from, and operates alongside, the existing Country-by-Country Reporting regime under which reports are submitted confidentially to the Malta Tax and Customs Administration.
Who is in scope?
Public CbCR applies to:
- Multinational groups with consolidated revenue exceeding €750 million in each of the last two consecutive financial years
- Standalone undertakings with total revenue exceeding €750 million in each of the last two consecutive financial years
- Non-EU groups with qualifying EU subsidiaries or branches
Certain exemptions may apply, including single-jurisdiction groups or entities already subject to equivalent disclosure frameworks.
When do the rules apply?
The first publication is expected in 2026 and refer to financial periods commencing on or after 22 June 2024.
Reports are required to be published within 12 months of the relevant balance sheet date.
Publication and filing requirements
In-scope entities must comply with a number of publication, accessibility and filing requirements.
These obligations are subject to specific timing, format and retention rules, making it important for organisations to establish appropriate processes to ensure ongoing compliance. Penalties for late submission and inaccurate information apply.
Determining the reporting entity
Responsibility for reporting typically lies with the ultimate parent undertaking.
However:
- Maltese subsidiaries or branches may assume responsibility where the parent is based outside the EU/EEA
- Alternatively, a single EU entity within the group may be designated to publish the report centrally.
In all cases, notification obligations to the Malta Business Registry must be carefully observed.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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