| 14 March, 2024

The CbC reporting deadline is drawing closer

As part of the OECD's framework to counter the transferring of profits to tax havens, a Country by Country (CbC) reporting mechanism has been established. OECD and G20 countries, including Poland, have committed to implementing this tool.

Who is subject to the CbC reporting obligation?

Entities subject to CbC reporting consist of groups of companies whose consolidated revenues in the previous financial year exceeded:

  • PLN 3,250,000,000.00 - if the group of companies prepares its consolidated financial statements in PLN,
  • EUR 750,000,000.00 or an equivalent of this amount - in all other cases.

What report do I have to file? By when?

There are two types of reports that can be submitted by electronic means only:

1/ CbC-P

An entity belonging to a group of companies, which has its registered office or management board in Poland, or a foreign entity conducting business in Poland through a permanent establishment (e.g., a branch of a foreign entity).

Within 3 months of the end of the reporting financial year of the group (by 31 March 2024*).

2/ CbC-R

The parent entity of the group (or designated entity) whose registered office or management board is located in Poland.

Within 12 months of the end of the reporting financial year (by 31 December 2024*).

*in the event the reporting year coincides with the calendar year

At the same time, it should also be noted that failure to fulfill the CbC reporting obligations may result in severe sanctions.

Should you have any additional questions relating to CbC reporting, please contact TIAS Tax Department at: office@tias.pl.