Associate Partner
Certified Tax Advisor, Lucanet.Certified Professional
RÖDL pCbCR Governance Suite
Large, multinational corporate groups are required to publish an income tax information report, also known as Public Country-by-Country Reporting (pCbCR). These requirements challenge companies to transparently and consistently prepare tax information. With the RÖDL pCbCR Governance Suite, we support you in preparing and disclosing pCbCR reports that are legally compliant and technically flawless.
Your governance solution for secure pCbCR reporting.
Management and the executive board are responsible for the substantive accuracy and timely disclosure of the income tax information report. At the same time, the legislator does not require a mandatory substantive audit of pCbCR by the statutory auditor. This means it is up to companies themselves to ensure robust processes, reliable data, and proper disclosure.
The RÖDL pCbCR Governance Suite addresses this issue. It helps companies create assurance not only in the final report but also throughout the entire reporting and disclosure process. The foundation is clear, robust process structures. These structures ensure consistent, traceable content. At the same time, it ensures the technically correct and EU-compliant publication of pCbCR.
pCbCR and tax CbCR, as components of transfer pricing documentation, are based on the same data and KPI foundation. The suite leverages this shared basis and links tax and public reporting through an end-to-end governance approach.
Your benefits at a glance
- Clearly structured, traceable end-to-end processes
- Reliable and consistent data foundation
- Confidence in content and disclosure
- Technically correct implementation in XHTML format
- Modular design that can be used individually or in combination
- An integrated team from Audit, Tax, GRC and Data
Assess. Protect. Disclose.
Security is not created in the report. It is created in the process.
The building blocks of your pCbCR Governance Suite
The RÖDL pCbCR Governance Suite is the building block of your secure pCbCR reporting. The modules cover the entire process – from design and quality of the report to technical disclosure – and can be used flexibly, combined with one another, and tailored to your governance requirements.
Process assurance pCbCR
Audit-oriented assurance of a stable and reproducible pCbCR reporting and disclosure process.
We review and assess the entire pCbCR reporting and disclosure process, including the underlying organizational structures and controls, to create a reliable, traceable foundation for your processes.
Key services:
- Analysis of the organizational structure and process flow of the pCbCR process
- Assessment of control design and effectiveness of key controls
- Identification of risks, inconsistencies, and process weaknesses
- Maturity assessment of the pCbCR reporting process
- Derivation of specific, prioritized recommendations for process improvement
Reporting assurance pCbCR
Audit assessment of the propriety and consistency of pCbCR content with a documented overall conclusion.
We review the income tax information report content for propriety, completeness, and consistency to create a reliable basis for public disclosure.
Key services:
- Review of the completeness and plausibility of the legally required disclosures
- Analysis of data aggregation and appropriate allocation by tax jurisdiction
- Review of calculation logic, derivations, and discretionary decisions
- Consistency check against the annual or consolidated financial statements
- Assessment of relevant controls in the reporting process
- Audit report with an overall conclusion on the propriety of pCbCR
Digital disclosure & advisory pCbCR
Technically valid implementation of pCbCR disclosure — combined with targeted expert advice.
We support you in the professional preparation of the information to be disclosed and take care of the technical creation and validation of the disclosure files for pCbCR.
Key services:
- Expert support with data collection and structured preparation
- Plausibility checks and substantive classification of the information to be disclosed
- Advice on scope, structure, content, and permissible disclosure options for pCbCR
- iXBRL tagging in accordance with the applicable EU requirements
- Conversion of the final content into the required XHTML format
- Technical validation and provision of the disclosure file
- Optional: Submission to the company register
Theresa Gäpel
Associate Partner
Certified Tax Advisor, Lucanet.Certified Professional
Your entry into pCbCR governance
Many companies are wondering how to approach pCbCR from organizational, process, and governance perspectives.
If desired, we can support companies in advance through a workshop to assess the maturity of their pCbCR governance and define the right configuration of the RÖDL pCbCR Governance Suite.
- Classification of pCbCR obligations from a governance, tax, and reporting perspective
- Clarification of roles and responsibilities (Executive Board, GRC, Tax, Accounting)
- Discussion of typical risks and weak points along the pCbCR process
- Derivation of a suitable use of the modules of the RÖDL pCbCR Governance Suite
For management and the supervisory board, it is crucial that pCbCR is based on a reliable reporting process with effective controls. Creating assurance in the process reduces errors, avoids unnecessary audit effort, and limits overall governance costs.
Steffen Freytag
Partner
Who is the pCbCR Governance Suite suitable for?
- Supervisory boards as well as executive boards and management teams
- CFO, tax, accounting and reporting
- GRC, compliance, ICS and tax CMS
- Data and digital leaders
Legal framework for pCbCR
The income tax information report must be disclosed in accordance with Sections 342 et seq. of the German Commercial Code (HGB). Management or the executive board is responsible for substantive accuracy and timely publication. For German stock corporations, a statutory substantive audit by the statutory auditor is not required; the supervisory board reviews substantive accuracy and proper disclosure. The technical requirements for publication arise from EU law.
FAQ on pCbCR
Who is affected by pCbCR?
pCbCR applies to large multinational corporate groups within the scope of Sections 342 et seq. HGB. In particular, companies are required to report if their consolidated revenue exceeds EUR 750 million in two consecutive financial years.
As a rule, anyone required to prepare a tax CbCR is also subject to the pCbCR reporting obligation.
From when is pCbCR mandatory?
pCbCR must be applied for the first time to financial years beginning after June 21, 2024.
When must pCcCR be disclosed?
In principle, pCcCR must be published in the company register within 12 months after the end of the respective financial year.
Which content must be disclosed in pCbCR?
Disclosures include, among other things, information on activities, number of employees, revenues, profit before tax, and income taxes paid and still payable per tax jurisdiction.
In which format must pCbCR be published?
pCbCR must be prepared and disclosed in machine-readable XHTML format with iXBRL tagging in accordance with the applicable EU requirements.
Who is responsible for pCbCR?
Management or the executive board is responsible for substantive accuracy and timely disclosure of pCbCR. For German stock corporations, the supervisory board oversees proper disclosure.
In addition, the supervisory board of a partnership limited by shares (KGaA) as well as the supervisory or administrative body of an SE must review the pCbCR and, where applicable, the statement regarding a missing legally compliant report. (Section 171(1) sentence 4 AktG; Section 47(4a) SEAG).
Is there a mandatory substantive statutory audit of pCbCR?
No. The legislator does not provide for a mandatory substantive audit of pCbCR by the statutory auditor. The required assurance must therefore be ensured through robust governance, process, and control structures within the company.
What sanctions apply for violations?
Violations of the obligation to prepare or publish pCbCR, as well as failures to disclose it in the company register, may be sanctioned by administrative fines of up to EUR 250,000.
What distinguishes pCbCR from tax CbCR?
Unlike tax CbCR under Section 138a AO, which is accessible only to the tax authorities, pCbCR is explicitly aimed at the general public.