As every year, we would like to remind you of the upcoming deadline for submitting the CbC-P notification for the previous financial year.

The CbC-P notification must be submitted electronically to the Head of the National Revenue Administration within three months following the end of the reporting financial year of the group. This means that for entities belonging to groups whose reporting year corresponds to the calendar year, the deadline for submission expires at the end of the current month.

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Meeting the CbC-P requirements is not a complex process. In order to fulfil this obligation, it is sufficient to indicate the reporting entity of the multinational group (i.e. the entity that will file the CbC-R report) and provide its identification details, including its address and the jurisdiction in which the CbC-R report will be submitted.

The entity indicated in the CbC-P notification has 12 months from the end of the reporting financial year to submit the CbC-R report. As a rule, the obligation to file the Country-by-Country Report rests with the ultimate parent entity. If the ultimate parent entity is not required to submit the CbC-R, the entity filing the CbC-P notification should designate itself as the reporting entity (or as the surrogate parent entity).

Who is required to file CbC-P?

The obligation to submit the CbC-P notification applies to entities that:

  • conduct business activity in Poland,
  • are members of a multinational enterprise (MNE) group, and
  • whose consolidated revenues in the preceding financial year exceeded:
  • PLN 3,250,000,000, where the consolidated financial statements are prepared in PLN; or
  • EUR 750,000,000 (or the equivalent in another currency), where the consolidated financial statements are prepared in a currency other than PLN.

Change of the ultimate parent entity during the year

What if the ultimate parent entity changes during the financial year?

In such a case, two separate CbC-P notifications must be submitted, each covering the period during which a given ultimate parent entity was responsible for the group. Each notification should indicate the ultimate parent entity applicable to the relevant period.

It is also important to note that if the respective ultimate parent entities apply different financial years, the deadlines for submitting the notifications may differ accordingly.

Method and deadline for submission

The CbC-P notification must be submitted exclusively in electronic form to the Head of the National Revenue Administration within three months from the end of the reporting financial year of the group.

Potential penalties for non-compliance

Failure to submit the CbC-P notification, as well as submitting incomplete or inaccurate information, may result in an administrative penalty of up to PLN 1 million (approx. EUR 230,000).

Furthermore, tax authorities are entitled to verify whether companies properly fulfil their obligations related to both the CbC-P notification and the CbC-R report.

With the deadline approaching, now is the right time to review your internal procedures and compliance processes. Proper preparation helps mitigate the risk of non-compliance and the associated adverse consequences.

Ultimate parent entities - new public CbC reporting requirements

For the vast majority of Polish entities, Country-by-Country obligations are limited to the submission of the CbC-P notification described above.

However, reporting entities responsible for filing the CbC-R must submit the report within 12 months following the end of the reporting financial year.

New regulations in this area were introduced by Directive (EU) 2021/2101 of the European Parliament and of the Council of 24 November 2021 amending Directive 2013/34/EU as regards disclosure of income tax information by certain undertakings and branches. These provisions have been implemented into Polish law through Articles 63l–63o of the Polish Accounting Act.

Under these regulations, ultimate parent entities or standalone entities (i.e. entities not forming part of a capital group) established in Poland are required to publicly disclose information on income tax paid and other relevant tax information where revenues reported in the annual consolidated financial statements exceed PLN 3,500,000,000 in each of the last two financial years. This obligation applies provided that at least one subsidiary or branch of the group is established or operates outside Poland.

As a rule, the obligation concerns ultimate parent entities. However, certain reporting obligations may also arise for subsidiary entities — for example where:

(i) the ultimate parent entity is located outside the European Economic Area (EEA), and

(ii) the income tax report is not made publicly available.

It is therefore advisable to monitor whether reporting obligations apply to a particular entity and whether they have been properly fulfilled at the group level.

The CbC-R report for FY2025 will need to be published in 2026, within 12 months after the end of the financial year.