This is to remind you that 2 April 2024 is the deadline for the filing of CbC-P notice to the Head of National Revenue Administration (Szef Krajowej Administracji Skarbowej).
In accordance with the Exchange of Tax Information with Other Countries Act of 9 March 2017 (Dz.U. 2023, poz. 241), CbC reporting obligation falls on any corporate group which:
- issues consolidated financial statements (or would issue such statements if the shares of at least one organisation within the group were traded on a regulated market);
- had consolidated revenue for prior financial year in excess of:
-
- PLN 3,250,000,000, or
- EUR 750,000,000.
In its CBC-P notice, a Polish group company will either:
- state it is the parent entity, the designated entity or some other entity filing a country-by-country report (CBC-R) for the entire group, or
- merely disclose the reporting entity or the country or territory where the CbC-R report will be filed.
The CbC-P notice must be filed within 3 months from the end of the reporting fiscal year of the group. If a group’s reporting year coincides with the calendar year, this deadline for 2024 will exceptionally fall on April 2 (as March 31 is a Sunday while April 1 is Easter Monday).
CBC-P may only be filed electronically using the eDeklaracje service. See here for the relevant form.
Importantly, an organisation that breaches the reporting duty by failing to file a CbC-P notice or by filing a CbC-P notice that is incomplete or not in accordance with the organisation’s data will be subject to a fine of up to PLN 1 million, imposed by decision of the Head of National Revenue Administration.
If this issue pertains to your business and you are interested in our assistance, please contact us.
This blog post is provided for general information purposes to keep you up-to-date with changes in tax law, tax rulings by authorities, case law of courts and interesting commentaries. Doradztwo Podatkowe WTS&SAJA shall not be held legally liable for any acts or omissions resulting from reliance on such information.