For multinational groups whose financial year coincides with the calendar year, two CbC deadlines expire on the same day: 31 December 2026. The country-by-country report for 2025 must be submitted, and the notification for 2026 must be filed. Groups that also file a Public CbCR with the Dutch Chamber of Commerce (KVK) face a third deadline on that same day.
For many tax departments, the country-by-country report is a recurring task. Yet things regularly go wrong in the final weeks of the year, often on points that have little to do with the figures themselves: an outdated XML schema, a missing connection to Digipoort or uncertainty about who within the group actually submits the report. You can still address these points calmly now.
The country-by-country report must be filed with the Dutch Tax Administration within twelve months after the end of the reporting year. For financial year 2025, that is 31 December 2026.
The notification is a separate obligation. Each Dutch group entity must report, no later than the last day of the reporting year, which entity within the group submits the country-by-country report. For reporting year 2026, that date is therefore also 31 December 2026. If a foreign entity submits the report, you provide that entity’s legal name, place of establishment and tax identification number.
The Public CbCR applies to financial years beginning on or after 22 June 2024. For most groups, financial year 2025 is therefore the first year they have to publish. You file the report with the KVK within twelve months and publish it on your own website.
Confirm who is filing. Check whether the ultimate parent entity, a surrogate parent entity or a Dutch entity files the country-by-country report, and whether the notification matches. After an acquisition, a restructuring or a relocation of the parent company, this is not always obvious.
Use the current XML schema. The Dutch Tax Administration publishes the technical requirements and the manual for submitting country-by-country reports at odb.belastingdienst.nl. Check that your software works with the current version before you build the file.
Make sure the figures match. Compare the totals in the country-by-country report with the consolidated financial statements. Differences can be justified, for example because of different consolidation boundaries, but you need to be able to explain them.
Take Pillar Two into account. Under the transitional CbCR safe harbour, your CbC data determines whether you can apply a simplified calculation in a jurisdiction. An error in the country-by-country report can cost you that simplification.
Validate well before the deadline. A file that fails the technical check is rejected. Validate in November or early December, so you have time to correct errors and resubmit.
Arrange the route to Digipoort. There is no public entry point for the country-by-country report, unlike for SBR annual financial statements. You need your own connection or a service provider that is already connected. Setting up your own connection takes time: certificates, testing and the connection itself.
Keep a record of what you submitted. Store the file you sent, the validation results and the confirmation of receipt. If the Dutch Tax Administration has questions, you can answer them right away, and you work from the same figures for the Public CbCR and the GIR.
For groups subject to the Dutch Minimum Tax Act 2024, the next deadline follows quickly. According to the Dutch Tax Administration, the GIR (in Dutch law the bijheffing-informatieaangifte or BIA) for financial year 2025 must be filed by 31 March 2027. The Dutch top-up tax return and payment are due by 31 May 2027. Like the country-by-country report, the GIR is submitted via Digipoort and relies largely on the same source data. A CbC process you set up properly now can be reused in the spring. Read how the different reporting flows fit together in CbC and GIR: how to manage 3 reporting streams from a single source.
Tax departments usually know the content of the country-by-country report well. What takes time in December is everything around it: the schema, the validation and the submission to the Dutch Tax Administration. SureSync Reporting validates your XML against the applicable CbC or GIR schema, submits it through a secure Digipoort connection and records every step in the portal. This works for a single group and for firms that submit on behalf of multiple clients. Read why this connection is not available as standard in Submitting CbC via Digipoort: why there is no standard entry point.
Want to know whether your submission is ready for 31 December? Schedule a consultation.