COUNTRY-BY-COUNTRY REPORTING

Are you part of a capital group and conducting business in multiple countries, including Poland? Are you planning to expand your business into Polish market? Are you wondering how to meet transfer pricing requirements?

Our expert team is here to streamline a process of transfer pricing compliance. As a comprehensive tax advisor, we can offer extensive services in the area of transfer pricing (Local file and Master file documentation, Transfer Pricing Analysis, TPR-C reporting and CBC reporting etc.).

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CbC

The concept of Country-by-Country (CbC) reporting was developed as part of the OECD action plan to counter base erosion and profit shifting (BEPS Action 13). As a result of implementing CbC reporting obligations, large international capital groups are required to provide aggregated data regarding the group to tax authorities.

1. CBC-R: COUNTRY-BY-COUNTRY REPORTING

Large multinational enterprises (MNEs) are required to submit an annual Country-by-Country (CbC) report, which provides a jurisdictional breakdown of key financial statement elements. A CbC report provides local tax authorities visibility to revenue, income, tax paid and accrued, employment, capital, retained earnings, tangible assets and activities.

📌 CbC-R deadline: The parent entity of a group of entities, headquartered or managed in Poland must submit information about the capital group (CbC Report) to the Polish tax authorities within 12 months from the end of the fiscal year.

📌 CbC-R general rules:

The obligation to prepare the so-called Country-by-Country Report (CbC-R) shall lie with the entities that belong to capital groups whose consolidated revenues in the financial year exceeded:

• PLN 3,250M – if the group prepares consolidated financial statements in PLN
• EUR 750M or equivalent – if the group prepares consolidated financial statements in another currency.

The report should be submitted in the country of the parent company, however, the capital group may designate another entity from the group to submit a CbC-R in the country of its residence.

2. CBC-P NOTIFICATION

Every Polish taxpayer (Polish permanent establishments included) belonging to a group (as defined above) required to prepare CbC-R will be bound to inform the Head of National Revenue Administration that:

• it is an ultimate parent company; or
• indicate the entity in charge of reporting and the country in which the information will be provided.

📌 CbC-P deadline: The CbC-P notification must be submitted within 3 months from the end of the group’s fiscal year.

How can we help?

We assist clients in verifying Country-by-Country (CbC) reporting in advance and ensuring the timely submission of CbC-R and CbC-P forms.

Additionally, we provide support in cases of failure to report within the statutory deadline.

Why choose CRIDO?

Extensive Experience in CbC reporting: Our team has in-depth expertise in Country-by-Country (CbC) reporting, supporting multinational enterprises in meeting their CbC-R and CbC-P obligations in Poland. We ensure that your reports are accurate, compliant, and aligned with both Polish regulations and OECD standards.

Accuracy & Risk Mitigation: CbC reporting involves detailed financial, tax, and operational data across multiple jurisdictions. We ensure correct data classification to align with OECD requirements, consistency across CbC-R, financial statements, and transfer pricing documentation and identification of potential red flags that could trigger tax audits.

Involvement of Partners & Managers: At CRIDO, senior transfer pricing specialists are actively engaged throughout the entire CbC reporting process. Their hands-on approach ensures that your reports are accurate and aligned with evolving regulatory expectations.

Contact us today to learn more about how we can assist you to achieve your business goals involving Poland in a safe way.