Polish members of multinational corporations need to make a CbC-P filing with Polish tax authorities (Head of National Revenue Administration). For entities whose fiscal year equals a calendar year the CbC-P filing for 2025 is due by 31 March 2026.
In accordance with the Exchange of Tax Information (Other Countries) Act of 9 March 2017 (Dz.U.2025.1379), the reporting obligation applies to groups which:
- consolidate their accounts (or would consolidate them if equity interests in at least one member of the group were traded on a regulated market), and
- reached the following minimum consolidated revenue in prior fiscal year:
- PLN 3.25bn, or
- EUR 750m.
Polish group members must make sure that their CbC-P filing indicates:
- whether the filer is the ultimate parent entity, a designated constituent entity or any other entity required to provide CbC reporting (CbC-R), or else
- the reporting entity and the country or territory in which CbC-R will be filed.
CbC-P must be filed within 3 months of the end of each fiscal year of the group.
CbC-P is filed exclusively in an electronic form via the e-Deklaracje system.
The failure to file a CbC-P or filing an incorrect or incomplete CbC-P may attract a penalty of up to PLN 1 million which is imposed by the Head of National Revenue Administration.
As the due date is approaching, you might want to check if your reporting obligations have been properly identified and the filing process has been duly planned for.
If these matters may be relevant to your business and you require assistance in assessing your reporting obligations or preparing any necessary reports, please contact our team or your WTS&SAJA consultant.
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.