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GRI 207: Tax · 2019
Disclosure GRI 207-4

Country-by-country reporting

Practical guidance for preparing this disclosure. Use this card to identify datapoints, verify claims and organise supporting evidence. For exact requirements, always refer to the official GRI source.

Dr Ross Kurinko, GRI Certified Trainer
Reviewed by Dr Ross Kurinko · GRI Certified Trainer LRA educational guidance · Not issued or endorsed by GRI
To prepare this disclosure
Disclosure focus

This disclosure asks an organisation to explain its tax position on a country-by-country basis, rather than only at group level. In practice, that means showing where the organisation operates and how its tax-related activity is spread across those jurisdictions, so readers can see the geographic pattern of its tax footprint and not just a single consolidated figure.

The practical focus is on coverage across the full organisation, not just a few flagship sites or major markets. The report should be broad enough to reflect the countries where the organisation has a material presence, so stakeholders can understand how tax is distributed across operations and where the organisation’s reporting is complete or limited.

This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official GRI source.

Before you start

A quick mental checklist before you prepare this disclosure — tick each as you settle it.

Preparation

Key datapoints to prepare

Datapoint What to capture Evidence hint Owner
Reconciliation note A plain explanation for any gap between the tax data reported here and the figures in the audited group accounts or other public financial filing. Tie-out schedule to the audited consolidated financial statements or filed public accounts, with a written explanation for each difference. Tax reporting
Resident tax locations Every tax country or territory where the entities in the audited group accounts, or in the public financial filing, are tax resident. Group structure chart, legal entity register and tax residency schedule aligned to the consolidated reporting perimeter. Tax reporting
Tax country The specific country or territory used for tax residency for the entity being reported. Legal entity tax file, residency certificate or tax registration record. Tax reporting
Resident entity names The legal names of the entities that are tax resident in the stated jurisdiction. Legal entity register and tax residency schedule. Tax reporting
Main business activities A short description of what the organisation mainly does in that tax jurisdiction. Management reporting, local entity profiles and business descriptions used in statutory filings. Tax reporting
Employee count The number of employees for the reporting basis used in this disclosure, as defined by the organisation’s chosen method. HRIS headcount report or payroll extract, with the counting method documented and dated. HR / People analytics
Counting method A clear description of how the employee number was calculated, including the population and counting rule used. Method note showing the source system, inclusion rules and any exclusions. HR / People analytics
External sales revenue Revenue earned from sales to customers outside the group for the tax jurisdiction. Local ledger, management accounts and revenue mapping to external customer sales. Finance
Tax expense accrued The corporate income tax charge recognised on profit or loss for the period in that jurisdiction. Tax provision workings, current tax journal entries and the tax note in the financial statements. Tax reporting
Intercompany revenue Revenue from sales between group entities that involve other tax jurisdictions. Intercompany billing records, transfer pricing reports and local ledger extracts. Finance
Pre-tax result The profit or loss figure before income tax for the period in the relevant jurisdiction. Local statutory accounts, management accounts or tax provision bridge to pre-tax profit/loss. Finance
Non-cash assets The value of tangible assets in the jurisdiction, excluding cash and cash equivalents. Fixed asset register and local balance sheet, with cash balances removed from the total. Finance / Fixed assets
Cash tax paid Corporate income tax actually paid in cash during the period for the jurisdiction. Tax payment confirmations, bank statements and cash tax ledger entries. Tax / Treasury
Tax difference explanation A short explanation of why the tax charge differs from applying the statutory rate to pre-tax profit or loss. Tax reconciliation working paper showing the main drivers and supporting schedules. Tax reporting
Period start date The first date covered by the information reported for this disclosure. Reporting calendar, consolidation timetable or disclosure pack cover sheet. Reporting / Finance
Period end date The last date covered by the information reported for this disclosure. Reporting calendar, consolidation timetable or disclosure pack cover sheet. Reporting / Finance
＋ Show GRI 207-4 sub-elements (LRA working checklist)

How to prepare it

1Set the reporting window first. Confirm the opening and closing dates for the period you are covering, and use that same window consistently across the disclosure.
2Fix the population you will report on. List every tax country where entities in the audited group accounts, or the publicly filed financial information, are tax resident.
3Define the data fields and the basis behind them. For each country, capture the resident entities, the business activities, employee count and how that headcount was worked out, plus the financial measures needed for the disclosure.
4Gather source evidence for each figure and narrative point. Pull the amounts, descriptions and supporting records from the group accounts, public filings and internal tax or finance workings so each reported item can be traced back.
5Prepare the explanation notes where needed. If any reported tax figure for the specified items does not tie to the audited group accounts or the public filing, write a clear reason for the gap; also explain why the tax charge differs from the amount implied by applying the statutory rate to profit before tax.
6Check the final pack against the official source before sign-off. Make sure the reported period, country list, entity names, activities, headcount basis, financial amounts and any difference explanations are complete, and record any exclusions or changes in method so the submission is transparent.
Request the data

Request the country-by-country tax pack

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

Can you provide the country-level tax and operating data for the reporting period, with a clear explanation for any differences against the group accounts or public filing figures?

Use your organisation’s own labels first (for example, legal entity, country, branch, market, statutory accounts, management accounts, tax provision, cash tax). Then map those terms to the reporting disclosure fields before sign-off. This is a possible LRA training template; adapt it to your organisation and check the source disclosure before sign-off.

Weak request

Please provide the country-by-country disclosure data for GRI 207-4, including all required metrics and explanations.

Why it fails: It uses framework language only, so the owner has to translate the ask from scratch. It does not say which internal files, systems, labels, or tie-out points are needed, and it gives no clue about the period, scope, or how to explain mismatches.

Better request

Please send the country-level tax pack for [period] for the entities in scope of the group accounts / public filing set. Use your normal finance or tax labels, and include a mapping note if your terms differ from the reporting table. We need the location, entity names, main activity, employee count and method, external and intercompany sales, profit before tax, tangible operating assets excluding cash, cash tax paid, tax accrued, and any explanation for differences against the group accounts or filed figures, plus the source file and dates covered.

Formal email template
Subject: Request for country-level tax and operating data for [period]

Hello [name],

We are preparing the sustainability reporting pack and need the country-level tax and operating data for [period] for the entities in scope of the group accounts / public filing set.

Please send a completed table covering each tax location in scope, with the following for each row:
- tax location label
- entity name(s)
- main activities
- employee count and the counting basis used
- external sales
- intercompany sales with other tax locations
- profit or loss before tax
- tangible operating assets excluding cash and cash equivalents
- cash tax paid
- tax accrued on profit or loss
- any explanation needed where the figures do not tie to the group accounts or public filing figures
- the start and end dates covered by the data

Please also include the source system or file used, the reporting basis, and any assumptions or exclusions.

If you use different internal terms, please keep your wording and add a short mapping note so we can align it to the reporting table.

This is a possible LRA training template; adapt it to your organisation and check the source disclosure before sign-off.

Many thanks,
[preparer name]
Short Teams / Slack version
Hi [name] — could you send the country-level tax pack for [period] for the in-scope entities? Please include: location, entity names, main activity, employee count + method, external sales, intercompany sales, profit before tax, tangible assets excl. cash, cash tax paid, tax accrued, and any tie-out notes to group accounts / filed figures. Add source file/system and the dates covered. Please use your own internal terms and add a quick mapping note. Thanks.
Industry examples
Manufacturing

Context. A group with factories, sales offices, and shared service centres across several countries.

Adapted request. Please provide the country-level tax pack for [period] for each in-scope legal entity and operating site. Use your usual finance labels for plant, office, and shared service locations, and add a mapping note. Include employee count and method, external sales, intercompany sales, profit before tax, tangible operating assets excluding cash, cash tax paid, tax accrued, and any tie-out notes to the group accounts.

Example response. A table by country showing each legal entity, site type, headcount basis, sales split, profit before tax, tangible assets excluding cash, cash tax paid, tax accrued, source system, and a note explaining that one country’s tax accrued differs because a local adjustment was booked after the group close.

Retail

Context. A group with trading subsidiaries, warehouse entities, and a central buying company.

Adapted request. Please send the country-level tax and operating data for [period] for the trading, warehouse, and central entities in scope. Use your internal labels for store, warehouse, and head office entities, and map them to the reporting table. Include employee count and basis, external sales, intercompany sales, profit before tax, tangible operating assets excluding cash, cash tax paid, tax accrued, and any explanation for differences to the filed figures.

Example response. A country table listing each entity, activity type, employee basis, external and intercompany sales, profit before tax, tangible assets excluding cash, cash tax paid, tax accrued, and a note that one jurisdiction’s figures differ from the filed accounts because a dormant entity was included in the filing set but had no trading activity.

Draft your disclosure

Notes that turn data into a disclosure

LRA training templates — adapt them to your organisation, and check the official source before sign-off.

Method note

State which entities are included, which tax locations they are treated as resident in, and the basis used for counting employees, sales, profit or loss, tax accrued, tax paid, and tangible assets so readers can see how each figure was built.

Context note

Explain what the figures show about where the group operates, where value is generated, and how the tax charge and cash tax compare with profit before tax across the jurisdictions reported.

Fluctuation statement

If any year-on-year movement is notable, point to the business or tax drivers behind it, such as changes in entity residence, headcount, sales mix, profits, asset base, or timing differences between tax accrued and tax paid.

Content index entry
GRI 207-4 Country-by-country reporting — [location / page] / [notes]
Download Centre

Preparation tools & forms

Professional preparation tools for GRI 207-4 — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI-assistant.

Free · Community members
01XLSPrep & Assurance workbookDatapoints, risks, evidence to check, owner and evidence pack.Get it free ↧ 02XLSData-request packRequest email, message template, response fields and sign-off structure.Get it free ↧ 03PDFLibrary CardPrintable one-page summary of this disclosure card.Get it free ↧
Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check
I reconciled the tax figures to the audited group accounts or the public filing, and I explained any gap where the numbers do not tie back exactly.Assurer checks whether the mismatch is real, whether the explanation is complete, and whether the reported figures were adjusted or simply presented differently without support.Reconciliation schedule between the disclosure and the audited accounts/public filing; working papers showing the source of each figure; written explanation for each difference; review notes from finance or tax sign-off.
I built the list of resident jurisdictions from the entities included in the audited group accounts or the public filing, and I checked that no resident location was left out.Assurer probes completeness of the entity population, whether any excluded entity should have been in scope, and whether residency was determined consistently.Entity register or consolidation perimeter; tax residency mapping by entity; group structure chart; evidence of review against the audited accounts/public filing; sign-off on the final jurisdiction list.
I used the local tax residence status for each included entity, based on the underlying records we held at the reporting date.Assurer checks whether the residence label is correct for each entity and whether the basis used was applied consistently across the group.Tax residence certificates or equivalent records; legal entity files; internal mapping showing how residence was assigned; dated source documents used for each entity.
I listed the resident entities using the legal names recorded in our group records, and I checked those names against the consolidation file before publication.Assurer probes whether entity names are current, whether trading names were used in error, and whether any entity in scope was omitted or duplicated.Legal entity register; consolidation pack; company registry extracts where relevant; final disclosure draft with reviewer comments; approval trail.
I described the organisation’s main lines of business using the same internal reporting basis that fed the rest of the disclosure.Assurer checks whether the activity description matches the group’s actual operations and whether it was prepared on a consistent basis with the other reported data.Management reporting pack; segment or business-unit descriptions; board or annual report narrative; internal review showing alignment between the activity summary and the reported figures.
I counted employees using the method we applied for this report, and I kept the calculation note so the figure can be traced back.Assurer probes whether the headcount basis was applied consistently, whether the population counted matches the stated method, and whether the figure is reproducible.Headcount methodology note; payroll or HR extracts; calculation workbook; cut-off date evidence; reviewer sign-off on the counting basis.

Evidence pack to prepare

Common reporting gaps

Figures are stated without the supporting narrative, or narrative without figures.Scope is inconsistent between the text and the numbers.The reporting boundary is left undefined.Material changes since the previous period are not disclosed.Estimates and measured values are not distinguished.Source records for the figures are not identified.
Common gaps

Mistakes to avoid when collecting the data

Wrong data owner
The team asks finance, tax, or local country leads in the wrong sequence and ends up chasing the person who can explain the figures rather than the person who holds the source records.
Framework terms, not business terms
The request is written in disclosure language instead of the organisation’s own labels, so the data owner cannot map it cleanly to the ledger, payroll, or entity list they actually use.
Unclear reporting boundary
The collector does not pin down which entities and jurisdictions sit inside the reporting set, so some resident entities are left out while others are counted twice.
Wrong reporting period
The data pull uses a different cut-off from the period covered by the disclosure pack, which makes the country figures and the supporting accounts impossible to line up.
Mixed counting basis
Headcount, tax, and revenue are gathered on different bases without noting the method for each field, so the numbers cannot be compared consistently across jurisdictions.
Source labels stripped out
The original names from the ledger, tax file, or local report are replaced too early, which makes it hard to trace each figure back to the record it came from.
Separate populations merged
Resident entities, intra-group flows, and third-party sales are rolled into one extract even though they need to stay distinct for the country schedule.
Missing evidence trail
The pack is saved without the supporting file names, dates, and version notes, so no one can show where each figure came from or who checked it.
No sign-off record
The draft moves forward without a clear approval trail from the people who prepared and reviewed the data, leaving no proof that the numbers were checked before use.

Where judgement is often needed

Set the group perimeter after a buy-in or sale
Decide which entities sit inside the reporting group for the period, and explain any change in the country list or figures caused by a takeover, disposal, or other perimeter shift.
Choose one country label where local definitions differ
If a place is described differently in local records, map it to one tax location for the report and explain the basis used so the same entity is not split or double-counted.
Handle entities that sit near the reporting boundary
For branches, dormant companies, or other close-call entities, state whether they are included with the relevant country or left out, and explain the rule used to make that call.
Fix the reporting date basis and keep it consistent
Use one cut-off point for the country table and explain if any figures come from a different timing basis, especially where local systems close on different dates.
Decide when to use actual figures and when to estimate
Where country data is incomplete, choose between measured amounts and reasonable estimates, then explain which lines are estimated and how that affects the totals.
State how employee counts are built
Explain whether headcount, average staff, or another internal method sits behind the employee number, and keep the same basis across countries unless a change is clearly described.
Explain how local accounting differences are bridged
If country figures are prepared under different local rules or ledgers, describe the adjustments used so the country table can be compared back to the group accounts or public filing.
Round figures in a consistent way
Apply one rounding approach across all countries and lines, and note it if rounding means the country totals do not exactly add up to the group total.
Aggregate where naming a unit would expose sensitive data
If naming a resident entity would create a privacy or confidentiality issue, combine it with other entities in the same country and explain the level of grouping used.
Examples

Illustrative examples

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative (synthetic) example — UK retail and distribution

Synthetic example only: we set out the tax places linked to our group companies, the activities they carry out, and the key figures for each place. Where the tax figures do not tie exactly to the audited group accounts, we explain the main cause of the gap below.

Use this as a pattern for a jurisdiction-by-jurisdiction breakdown. Keep the explanation for any mismatch brief but specific, and make sure the figures can be traced across the table.

Illustrative (synthetic) example — Renewable energy and utilities

Synthetic example only: we present the resident group companies by tax place, the work they do, and the main tax and operating figures. The difference between tax accrued and tax paid is explained because the cash figure and the accounting figure do not match exactly in this illustration.

Use this as a second pattern for a capital-intensive group. If the tax charge and cash tax differ from the amount implied by the local rate, say why in plain language and keep the explanation tied to the numbers shown.

Company reports

How companies report GRI 207-4

Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.

ERG S.p.A.
Electric Utilities / IPP / Energy Traders · Italy · 2025
Open report →
ERG S.p.A.'s Integrated Report 2025 includes reported monetary values related to tax liabilities and provisions for disposed businesses, specifically noted on page 222. The report also references financial statements and directors’ reports with independent auditor statements on page 305, indicating some level of assurance. However, there is no clear or quotable narrative or detailed methodology found in the report regarding other specific disclosure items, and several expected narrative and numeric datapoints are missing or unclear.
Endesa, S.A.
Electric Utilities / IPP / Energy Traders · Spain · 2025
Open report →
Endesa, S.A.'s 2025 Consolidated Annual Report includes some narrative information relevant to the disclosure, notably on page 15 where the Consolidated Financial Statements Audit Report is presented, and on page 559 which details other current financial assets. However, the report lacks quotable evidence for most specific narrative and monetary datapoints related to the disclosure, with no clear methodology or detailed figures found elsewhere. Several expected narrative items and monetary values are not addressed or are unclear, limiting the completeness of the disclosure in this report.
JSW Steel Limited
Mining — Iron, Aluminum, Other Metals · India · 2025
Open report →
JSW Steel Limited’s Integrated Annual Report FY 2024-25 includes some narrative related to financial statements and unaudited financial information for two subsidiaries, as noted on page 273. The report also references the audit of consolidated financial statements and responsibilities of auditors and joint ventures on pages 272 to 274. However, there is no quotable evidence found in the report for specific narrative items, numeric values, or monetary values related to the disclosure, and the methodology or detailed narrative remains unclear.
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Check your understanding

Scenarios to work through

A group has subsidiaries in three tax locations. In one location, the local ledger shows £12 million of sales to outside customers and £3 million of sales to other group entities, but the consolidated pack only shows the outside-customer figure.

QShould the country table include both revenue figures for that location, and if the group uses only the outside-customer number in the published report, what should the preparer do about the mismatch?
Reveal model answer →

A preparer is building the country schedule for a year ending 31 December 2025. One subsidiary moved its tax residence from one jurisdiction to another during the year, and the finance team is unsure whether to list both places or only the year-end location.

QHow should the preparer decide which tax locations to include, and what supporting details belong with each location entry?
Reveal model answer →

In one jurisdiction, the payroll system counts 48 full-time staff and 6 part-time staff, while the HR dashboard shows 51 people on an average-headcount basis. The tax reporting pack also includes a note that the figure is based on year-end headcount.

QWhich employee figure should be used in the country table, and what extra explanation should accompany it?
Reveal model answer →

For a tax jurisdiction with profit before tax of £20 million, the tax team calculates current tax accrued of £4 million, but the amount that would arise by applying the local statutory rate to profit before tax is £5 million. The difference is driven by a tax incentive and a non-deductible expense.

QWhat should the preparer explain in the country table, and what should they avoid doing?
Reveal model answer →
Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

GRI
GRI 207-4
within GRI 207: Tax
Open official source →
Primary
Related & explore
FAQ

Questions this page answers

How do I use the GRI 207-4 Tax page to prepare the disclosure from scratch?+
What data do I need to collect for GRI 207-4 Tax before I start drafting?+
How should I decide the scope for the GRI 207-4 Tax data set?+
Who should own the GRI 207-4 Tax inputs in practice?+
What should I put in the evidence pack for GRI 207-4 Tax assurance?+
What are the most common mistakes people make when drafting GRI 207-4 Tax?+
How do I use the Prep & Assurance workbook for GRI 207-4 Tax?+
What can I use the printable Library Card for on GRI 207-4 Tax?+
How do I turn the GRI 207-4 Tax data into a draft disclosure?+
Can I reuse GRI 207-4 Tax data for ESRS G1 Business Conduct reporting?+
More questions this page can help with
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