Comply, Refuse, or Defer: First Evidence on EU Public Country-by-Country Reporting

The European Union's Public Country-by-Country Reporting (CbCR) Directive aims to make where multinationals operate and where they pay tax visible to investors, regulators, and the public. This report asks whether the Directive delivers on that objective, examining three questions: does the regime add new public information, how complete is the disclosure, and how much of multinational activity does its geographical design make visible? Using the first comprehensive dataset of public CbCR filings under the Directive — 144 multinationals from 24 headquarters countries, covering financial years 2023 and 2024, for a total of 164 reports, drawn from Romania's early transposition — three findings emerge. First, the Directive adds new public information, since most multinationals now publishing have no prior voluntary disclosure history, but coverage falls short of its theoretical scope: only 20% of the 569 non-EU multinationals estimated to be in scope have published a report. Second, 38% of reports are incomplete, most commonly limited to Romania only, driven mainly by parent non-cooperation and safeguard clause invocations. Third, the Directive's geographical design leaves a large share of multinational activity aggregated into a residual "Others" category, which absorbs 71% of profits and 74% of revenues in the Romanian data. The report recommends the Commission's review prioritise widening disclosure, addressing parent non-cooperation, and establishing a centralised repository for filings.