Upcoming CBC-P Reporting Deadline: Increased Information Obligations

Upcoming CBC-P Reporting Deadline: Increased Information Obligations

The CBC-P notification must be submitted to the Head of the National Revenue Administration (Szef KAS) within three months of the end of the financial year. For entities whose financial year aligns with the calendar year, the deadline is March 31, 2025.

The obligation to submit the CBC-P notification is part of broader reporting requirements associated with the implementation of the Country-by-Country Reporting (CbCR) mechanism by OECD member states.

Through the CBC-P notification, entities within capital groups subject to Country-by-Country Reporting must inform the Head of the National Revenue Administration about which entity within their group will submit the CBC-R report and in which country it will be filed.

The CBC-P reporting obligation, with a deadline of March 31, 2025, applies to entities belonging to a capital group whose consolidated revenue for 2023 exceeded:

• PLN 3,250,000,000 (if the consolidated financial statement is prepared in PLN), or
• EUR 750,000,000 (or the equivalent amount in another currency).

The CBC-P notification must be submitted electronically via the e-Deklaracje system. The form requires details on the purpose and period of submission, information about the reporting entity, and details regarding the entity within the group responsible for submitting the CBC-R report.

Failure to submit the CBC-P notification or providing false information within it may result in a significant financial penalty of up to PLN 1,000,000.

The deadline for submitting the CBC-R report by the designated entity within the group is longer—12 months from the end of the financial year. The CBC-R report includes detailed information on the capital group, organized by country of residence of its entities, such as:

• Comprehensive financial data of the entities,
• A list of entities with tax identification numbers and registered addresses.

The ultimate parent entity of the group submits the CBC-R report in its country of residence.

New Public CBC Reporting Regulations

Pursuant to EU Directive 2021/2101, new public CBC reporting regulations have been introduced. Starting from the financial year commencing after the directive’s effective date (i.e., after June 22, 2024), ultimate parent entities and certain subsidiaries will be required to prepare or publish reports that must be submitted to the National Court Register (KRS) and posted on the websites of the obligated entities.

Public CBC reports will include information on:

• Description of the capital group’s activities,
• Number of employees,
• Revenue, including transactions with related parties,
• Pre-tax profit or loss,
• Amount of corporate tax due and paid,
• Amount of undistributed profits.

In Poland, for most entities, the first public CBC reporting obligation will apply to the 2025 financial year, with a deadline at the end of 2026.

The detailed scope of data subject to reporting and the entities obligated to disclose it are specified in Articles 63l-63o of the Accounting Act.

It is advisable to verify, in advance, whether your entity falls under the new regulations and to initiate the process of collecting the necessary information for publication. We offer support in fulfilling obligations related to the Country-by-Country Reporting system.