Public Country-by-Country Reporting (pCbCR): ASCG submits its comment letter

On 5 September 2024, the ASCG submitted a statement on the draft implementing act on public country-by-country reporting (Directive (EU) 2021/2101).

In its statement, in addition to a number of technical improvements, the DRSC draws attention to the high costs of preparing and analysing this type of reporting, and also calls for longer consultation periods to be granted in future. The draft was published by the European Commission on 2 August 2024 with an initial comment period of just four weeks.

Background:

Certain undertakings are required to publish an income tax report within one year of the end of their financial year (Sections 342 et seq. German Commercial Code). Details are to be regulated by an implementing act of the European Commission (Section 342l German Commercial Code). The ASCG submitted a statement on both the then proposed directive and the draft bill to transpose the EU directive into German law (both in German only). In 2023, when the German implementation process was finalized, we further published a briefing paper on pCbCR (also available in German only).