This is to draw your attention to regulations on public reporting on income tax information (Public CbC Reporting).

The new Public CbC Reporting framework has been implemented into Polish Accounting Act based on EU Directive 2021/2101. It provides for a new reporting obligation on top of the existing CbC-R requirements.

Public CbC Reporting – who is required to comply?

The following entities are under an obligation to provide Public CbC Reporting:

  • Polish ultimate parent undertakings / standalone undertakings whose consolidated revenue exceeded PLN 3.5bn in each of the last two financial years, if they have foreign subsidiary undertakings / branches;
  • ultimate parent undertakings / standalone undertakings which are established or have their place of management outside EEA (e.g. in Japan, Switzerland, USA or China), if:
    • they have a subsidiary undertaking or branch in Poland (or in any other EEA country), and
    • the ultimate parent undertaking’s / standalone undertaking’s consolidated revenue exceeds EUR 750 million in each of the last two financial years;
  • the reporting obligation may pass to other entities, such as:
  • a Polish subsidiary undertaking which in the last two financial years exceeded at least 2 of the 3 thresholds for being classified as a “small undertaking” for the purposes of the Accounting Act, i.e.:
    • PLN 33 million in total assets on the balance sheet as at the end of the financial year,
    • PLN 66 million in net revenue from sales of goods during the financial year,
    • an average annual headcount of 50 FTEs;
  • a Polish branch whose revenue exceeded the small undertaking threshold (PLN 66 million) under the Accounting Act in the last two financial years.

When is a subsidiary undertaking / branch exempt from Public CbC Reporting?

A Polish subsidiary undertaking / branch is not required to provide Public CbC Reporting if the ultimate parent undertaking / standalone undertaking:

  • has issued the Public CbC Report and published it on its website within the statutory deadline and in accordance with applicable regulations, and
  • identifies the name and the registered office of a subsidiary undertaking within EEA which has been appointed to file the Public CbC Report in the relevant register.

If the parent undertaking fails to comply with Public CbC Reporting obligations, the Polish subsidiary undertaking / branch shall request relevant details from it or, if none are provided, shall issue the income tax information report by itself based on available information and disclose the parent’s failure to provide details.

Reporting deadlines and venue

  • The report must be filed with relevant commercial register and published on-line within 12 months from the balance sheet date. Once published on-line, it must remain so posted for at least 5 years.
  • The reporting obligation applies to all financial years beginning after 21 June 2024.

For companies whose financial year coincides with the calendar year, the first Public CbC Report (for 2025) is due by 31 December 2026.

If you would like to discuss any matters of Public CbC Reporting, do not hesitate to 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.