This note concerns Country-by-Country Reporting (“CbCR”), particularly the Portuguese regime, the postponement of reporting duties, potential legal changes due to the EU Directive regarding CbCR and, lastly, the recent decision by the French Conseil Constitutionnel that decided for the unconstitutionality of the public part of the French CbCR regime. Such public nature of CbCR is also being pursued by the European Union.

This regime is one of many pieces being put in place in favour of tax transparency but its public format has now encountered a substantial obstacle regarding its proportionality.