All firms subject to CRD IV will need to publish information on activities, turnover and employees by 30 June 2014 whilst global systemically important institutions (“G-SIIs”) will in addition need to report information on profits and tax payments by the same date, albeit on a confidential basis. Subject to approval by the European Commission all firms subject to CRD IV will need to publish information on tax payments from 1 January 2015.
It is possible that initial reporting will include information for the current financial year and hence firms will need to consider whether systems are capable of supporting the required reporting and develop a strategy to explain the information to be put into the public domain and respond to public commentary.
The next step is for HM Treasury to publish a consultation document, hopefully with draft implementing regulations. This is currently expected in early or mid September but this could slip.
- More detailed Q&A can be found in CRD IV: Country-by-country Reporting (PDF 95KB)