CbC Reporting Thresholds 2026: Comparison by Jurisdiction

There is no single CbC reporting threshold. Every jurisdiction that implemented BEPS Action 13 wrote its own domestic trigger, and while the OECD’s original benchmark — EUR 750 million in consolidated group revenue — is the figure almost everyone quotes, several of the largest CbC jurisdictions never actually pegged their rule to that euro amount. The United States set an independent dollar threshold. Australia uses a different legal concept entirely. And the United Kingdom’s regulation doesn’t contain a fixed sterling figure at all, despite what a lot of secondary sources claim. Tax and compliance teams that assume “€750 million, or its local-currency equivalent” applies uniformly get the scoping question wrong more often than the underlying CbC rules would suggest.

The OECD Baseline: EUR 750 Million, Set in 2015

BEPS Action 13 established country-by-country reporting as a minimum standard within the OECD/G20 Base Erosion and Profit Shifting Project. The recommended threshold — EUR 750 million in consolidated group revenue for the fiscal year preceding the reporting period — was designed to capture roughly the largest 10-15% of MNE groups by revenue while keeping the compliance burden off mid-market multinationals. Jurisdictions transposing the standard domestically were instructed to use “a near equivalent amount in domestic currency as of January 2015,” which is why so many local rules cite a threshold that looks arbitrary in the national currency but traces back to the same euro figure.

The OECD maintains its own reference materials on the standard and its jurisdiction-by-jurisdiction implementation status through its country-by-country reporting hub. The European Union transposed the identical figure into binding law through Council Directive 2016/881 (DAC4): MNE groups with total consolidated revenue of EUR 750 million or more and a presence in the EU fall within scope, as confirmed on the European Commission’s own DAC4 page.

CbC Reporting Thresholds by Jurisdiction (2026)

The table below covers the jurisdictions with the highest compliance relevance for multinational tax departments — the largest CbC-reporting economies plus the ones where the domestic rule departs, in some way, from the plain EUR 750 million story. Every figure links to the primary source that states it; where an official source didn’t give us a verifiable number, the jurisdiction isn’t listed rather than guessed at.

Jurisdiction CbC reporting threshold Basis Source
OECD / BEPS Action 13 (baseline) EUR 750 million consolidated group revenue Recommended minimum standard; each jurisdiction transposes it domestically OECD
European Union (DAC4) EUR 750 million consolidated group revenue Council Directive 2016/881, binding across all EU member states European Commission
United States USD 850 million or more of revenue in the preceding annual reporting period Independent dollar figure — not defined as a conversion of EUR 750 million IRS
United Kingdom EUR 750 million, converted into the group’s reporting currency at the average exchange rate for the accounting period — the regulations set no fixed GBP figure The Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) Regulations 2016, Regulation 4 UK legislation
Canada More than EUR 750 million in consolidated group revenue in the immediately preceding fiscal year Income Tax Act s. 233.8 / CRA guidance, stated in euros rather than a fixed CAD figure Canada Revenue Agency
Australia AUD 1 billion or more in annual global income “Significant Global Entity” (SGE) test — a broader domestic concept than the OECD €750m benchmark, not a currency conversion of it Australian Taxation Office
Switzerland CHF 900 million turnover for groups with a Swiss parent Federal Act on the International Automatic Exchange of Country-by-Country Reports Swiss Federal Tax Administration (ESTV)
Singapore SGD 1,125 million consolidated group revenue in the preceding financial year IRAS e-Tax Guide on Country-by-Country Reporting IRAS
Japan JPY 100 billion in total revenue for the Ultimate Parent Entity’s preceding fiscal year “Specified MNE Group” definition National Tax Agency (Japan)
Hong Kong EUR 750 million, or HKD 6.8 billion, consolidated group revenue for the preceding accounting period Inland Revenue Ordinance, CbC reporting provisions Hong Kong Inland Revenue Department

Dozens of other jurisdictions — including most EU member states individually, plus countries such as Spain — apply the same EUR 750 million standard through their own domestic legislation rather than a separately negotiated figure. Some non-OECD-aligned jurisdictions set their own local-currency thresholds independently; Indonesia is one example where the domestic rule is worth checking directly rather than assuming a straight euro conversion.

Which Jurisdictions Actually Break From the EUR 750 Million Standard?

Two matter more than the rest for scoping purposes. The United States set USD 850 million as a flat figure in the Treasury regulations implementing Form 8975 — this was calibrated to be roughly commensurate with EUR 750 million using 2015 exchange rates, but it does not move with the euro afterward, and Treasury has not indexed it since. Australia’s “Significant Global Entity” test is a different animal altogether: it’s a domestic concept that predates and extends beyond CbC reporting (it also governs penalty regimes and other disclosure obligations), set at AUD 1 billion of annual global income rather than defined as a conversion of the OECD figure at all.

Everyone else in the table above — the EU, the UK, Canada, Hong Kong — either states the threshold directly in euros or converts it mechanically at a specified exchange rate. That distinction matters operationally: a group hovering near USD 850 million or AUD 1 billion is tracking a fixed bar, while a group hovering near EUR 750 million (or its floating local-currency equivalent) can move in or out of scope purely on currency movement, without any change in underlying business size.

Why “The UK Threshold Is £586 Million” Is the Wrong Way to Put It

A specific sterling figure circulates widely in secondary commentary on UK CbC reporting. It isn’t in the law. The Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) Regulations 2016 set the threshold at EUR 750 million and specify, in Regulation 4(2), that where a group’s consolidated financial statements are prepared in a currency other than euros, the reference to €750 million “has effect as if it referred to the equivalent in that currency at the average exchange rate for the accounting period.” There is no fixed GBP number written into the regulation — the sterling-denominated figures that circulate are administrative estimates at a point in time, not the legal threshold, and they go stale every time GBP/EUR moves. A UK group assessing scope should run the actual average-rate conversion for its own accounting period rather than compare its revenue to a remembered sterling figure from a previous year.

What Counts as “Consolidated Group Revenue” for CbC Purposes?

The threshold applies to total consolidated group revenue as reported in the Ultimate Parent Entity’s consolidated financial statements for the fiscal year immediately preceding the reporting fiscal year — including revenue from sales of inventory and property, services, royalties, interest, premiums, and any other amounts, and generally including extraordinary and non-operating income depending on the applicable accounting standard. Most implementing jurisdictions follow the OECD’s Action 13 guidance closely on this point, but the treatment of specific items (gains on disposals, certain financial income) can vary by domestic rule, which is a detail worth confirming locally rather than assuming uniformity — this article covers scoping thresholds, not the full definitional mechanics of “revenue” jurisdiction by jurisdiction.

Practical Implications for Tax and Compliance Teams

Three consequences follow directly from the structure above. First, groups with revenue in the EUR 700-800 million range in any given year should track the actual threshold in the reporting currency for every jurisdiction where they have a filing or notification obligation — not just the euro figure — since a floating local-currency conversion can pull a group into or out of scope even when consolidated revenue in euros hasn’t moved. Second, groups near USD 850 million or AUD 1 billion are watching fixed, non-floating bars, which makes threshold monitoring simpler but means there’s no currency cushion if underlying revenue grows. Third, a group can be out of scope in its parent jurisdiction and still face local filing or notification obligations elsewhere if a constituent entity’s jurisdiction has a lower local threshold or imposes secondary filing requirements — threshold-testing needs to happen at the group level globally, not just where the Ultimate Parent Entity sits.

Frequently Asked Questions

What is the CbC reporting threshold under BEPS Action 13?
The OECD’s recommended minimum standard is EUR 750 million in consolidated group revenue for the fiscal year immediately preceding the reporting period. Jurisdictions implementing the standard domestically either adopt this euro figure directly, convert it into local currency, or — in a minority of cases, such as the United States and Australia — set an independent local threshold not defined as a conversion of it.

Does the CbC reporting threshold change every year?
The underlying EUR 750 million benchmark itself has not been revised since BEPS Action 13 was finalized in 2015. What changes, in jurisdictions that convert the euro figure into local currency at a floating rate (such as the UK), is the local-currency equivalent for each accounting period, which moves with the exchange rate. Fixed-figure jurisdictions such as the US (USD 850 million) and Australia (AUD 1 billion) do not adjust their threshold for currency or inflation.

What happens if a group’s revenue is just below the threshold?
No CbC report or notification is required for that fiscal year. But because several major jurisdictions use a floating local-currency conversion of EUR 750 million, a group with consolidated revenue stable in euro terms can still cross the threshold in a given jurisdiction purely because of exchange-rate movement between accounting periods — this is why threshold monitoring needs to be run annually per jurisdiction, not assumed to carry over from the prior year.

Is the CbC reporting threshold the same as the Pillar Two GloBE threshold?
No. BEPS Action 13 country-by-country reporting and the Pillar Two GloBE Information Return are separate reporting regimes with separate thresholds, separate forms, and separate filing mechanics, even though both commonly use the same EUR 750 million revenue test as their entry point. A group in scope for one is very likely, but not automatically, in scope for the other — each regime’s own rules should be checked independently.

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