UK multi-national entities: new reporting requirements – deadline 31 December 2026

Large UK-headquartered multi-national enterprises must now disclose their global tax affairs publicly, as mandated by the EU Public Country-by-Country Reporting Directive. Formally introduced into UK law in 2016, the first reporting deadline for most calendar-year taxpayers is 31 December 2026, applying to financial years starting on or after 22 June 2024.

The objective is to enhance transparency regarding where profits are generated and where corporate income tax is paid, both in and outside the EU.

Which UK multi-national entities are affected

UK-headquartered multi-national enterprise groups with annual consolidated revenue of €750 million or more are required to file a report for each accounting period in which they meet the threshold. Where the ultimate parent entity is based in a jurisdiction that does not require country-by-country reporting, or where exchange agreements are not in place or not functioning effectively, UK entities may also have a local filing obligation.

The UK continues to refine its country-by-country reporting regime and is positioning itself in line with global transparency trends. Although traditional country-by-country reporting is confidential, policy discussions and commentary suggest the UK may follow the EU and Australia in adopting public reporting measures, signalling a continued focus on tax transparency and anti‑avoidance.

UK multi-national groups with EU-based companies

For UK-headquartered groups with subsidiaries or branches in an EU member state, it is generally acceptable that the UK parent publishes the report on its own website and assigns one of the qualifying EU subsidiaries or EU branches to file the report with their national trade registry.

For EU-headquartered groups, the ultimate EU parent company must prepare and publish the report in its own EU member state. It is crucial for groups to identify the reporting entity in a timely manner and ensure that internal processes are aligned accordingly.

Reporting requirements

For each relevant jurisdiction, the following information must be disclosed:

• Brief description of activities;
• Number of full-time equivalent employees;
• Revenues (including related party revenues);
• Profit or loss before income tax;
• Income tax accrued for current financial year;
• Income tax paid;
• Accumulated earnings.

This information must be presented:

• Separately for each EU member state;
• Separately for each jurisdiction included on the EU list of non-cooperative jurisdictions for tax purposes or “grey list” jurisdictions (if listed for two consecutive years);
• On an aggregated basis for all other jurisdictions.
• Publicly accessible free of charge for five years in iXBRL format.

How Moore Kingston Smith can assist

Given the required data collection, technical formatting, internal validation and coordination across jurisdictions, it is advisable to initiate preparations well ahead of the December 2026 reporting deadline.

At Moore Kingston Smith, our international tax experts ensure that your UK and any EU operations comply fully with the EU Public Country-by-Country Reporting Directive.

Our service includes:

• determining if the group falls within the scope;
• identifying the responsible reporting entity;
• analysing applicable local rules;
• preparing the report;
• aligning with other reporting obligations;
• iXBRL tagging and publication compliance.

Contact us to discuss your specific situation.

Further information

HMRC’s International Exchange of Information Manual provides detailed guidance on scope, filing obligations, OECD alignment, notifications and exchange arrangements. The manual outlines which entities must file, the applicable thresholds and how HMRC uses country-by-country data for risk assessment and compliance purposes.