Tax transparency has reached a new level with the introduction of a new form of reporting. For multinational enterprise groups, the introduction of Public Country-by-Country Reporting (Public CbCR) is not merely another compliance task, but a fundamental change. Until now, CbC reports were submitted by the group exclusively to the tax authority and the disclosure of data took place confidentially. From now on, however, this information will become publicly available to everyone. In Hungary, the situation is particularly interesting, as the domestic legislator has set a deadline that may create significant challenges for companies.
Public CbCR does not affect everyone – but those it does affect have no room for manoeuvre
The Public CbCR rules apply to multinational enterprise groups whose consolidated annual revenue exceeds EUR 750 million in two consecutive financial years. Where the ultimate parent undertaking itself falls within the scope of the Hungarian Accounting Act, the threshold is HUF 275 billion – however, this threshold applies exclusively to that case, where the Hungarian parent undertaking is itself obliged to prepare the consolidated group report, and does not constitute a threshold applicable to subsidiaries or branches.
It is important to emphasize that Hungarian subsidiaries may also be subject to the obligation even if their ultimate parent undertaking is registered outside the European Union – for example, in the United States or Asia. In such cases, the Hungarian entity must arrange for the publication of the report, which often poses a serious internal coordination challenge, as the required data must be obtained from the group headquarters. The same applies to Hungarian branches of non-EU groups – with the important additional point that a branch is only required to publish in Hungary if the group has no other subsidiary registered in an EU Member State that already fulfils this obligation.
Why is the Public CbCR report sensitive?
The scope of data to be disclosed is familiar: revenue, broken down into related-party and third-party revenue; profit or loss before tax; corporate income tax paid and accrued; number of employees; and accumulated earnings. The difference does not lie here.
What makes Public CbCR special is that these data are published in a standardised, machine-readable format. This means they enable automated comparisons, differences between countries become immediately visible, and the figures may be interpreted even without context.
It is important to clarify that this is not a new tax authority tool for transfer pricing audits. At the same time, it provides an appropriate basis for external stakeholders – the media, investors or NGOs – to develop their own interpretations based on the published data.
It should also be taken into account that Public CbCR must be prepared in accordance with the uniform data structure and publication requirements defined by the European Commission, in a machine-readable electronic format based on XHTML/XML, as provided for in Section 134/F(4) of the Hungarian Accounting Act. In practice, this does not mean completing a traditional form, but rather producing a structured, tagged dataset that requires accurate preparation from both a technical and a content perspective.
The Hungarian Public CbCR peculiarity: the bottleneck is not the rule, but the timing
One of the most critical aspects of Public CbCR in Hungary is the deadline.
The EU Directive would generally allow a 12-month publication period for publication on the website of non-EU parent undertakings – however, this functions only as an exemption condition, not as a general deadline. Under the Hungarian Accounting Act, the affected Hungarian companies must file and publish the report containing corporate income tax information at the same time as their annual financial statements or consolidated annual financial statements. For calendar-year taxpayers, this means in practice:
- for standalone undertakings: 31 May 2026
- for parent undertakings preparing consolidated financial statements: 30 June 2026
. This is particularly true where the non-EU parent undertaking will fulfil its own publication obligation, but will do so according to its own – possibly different – deadline. In this situation, the Hungarian subsidiary cannot rely on the parent undertaking's publication: the Hungarian deadline applies, and the obligation must be fulfilled independently. Where the ultimate parent undertaking is established under the law of an EU Member State, no independent publication obligation arises for the Hungarian subsidiary under Section 134/E of the Hungarian Accounting Act – the obligation rests with the parent undertaking.
What happens if the parent undertaking does not provide the data in time?
If the group’s ultimate parent undertaking – in the case of a non-EU parent undertaking – does not provide the necessary information in time, the Hungarian subsidiary must still fulfil its publication obligation. In such cases, the Hungarian Accounting Act allows the publication of a so-called “statement of non-cooperation”, which documents that the subsidiary requested the data, but they were not made available. This is not an exemption – the publication obligation remains in place – but rather a clear record of responsibility.
Public CbCR deadline – what should companies do now?
The regulation applies to financial years starting on or after 22 June 2024, which for most calendar-year companies means that the first affected year will be the financial year ending on 31 December 2025. Accordingly, the first Public CbCR publication deadline for calendar-year companies will fall at the end of May 2026.
In practice, this means a shorter preparation period than it may first appear, especially considering the time required for group-level data collection, internal reconciliations and audit processes.
Affected companies should already start preparing for publication in a structured manner. In this process, it is advisable to:
- determine which Public CbC obligation category the Hungarian entity falls into;
- map what data will be required from the group headquarters and according to what timeline these data will become available;
- designate the organisational unit or person responsible for the publication process
Hungarian regulation links publication to the domestic accounting deadline, leaving local companies with a narrow timeframe to obtain the necessary data in time.
