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2024-03-27

CbC Notification – Attention to the Approaching Deadline

Business Law Regulations Tax advisory

This is the final call to fulfill one of the reporting obligations within the area of transfer pricing—submitting the CbC-P notification, which pertains to the obligation to provide information about the corporate group.

Subject Scope

The obligation to submit the CbC-P notification applies to entities that are part of multinational corporate groups, provided that their results are consolidated in the group’s financial statements and the consolidated revenues of the group in the previous financial year exceeded PLN 3,250,000,000 (if the corporate group prepares consolidated financial statements in Polish zlotys) or EUR 750,000,000 or its equivalent (in other cases).

In such cases, the taxpayer must notify the Head of the National Revenue Administration whether:

  • It is the parent entity, the designated entity, or another entity submitting the information for the entire group (CbC-R); or

  • It designates the reporting entity and the country or territory where the CbC-R report will be filed.

Deadline for Compliance

The CbC-P notification must be submitted within 3 months after the end of the group’s financial year. Therefore, if the financial year aligns with the calendar year, the deadline for submitting the CbC-P for 2023 is April 2, 2024.

Submission Format

The CbC-P notification must be submitted electronically through the e-Declaration system. It is not possible to submit it via the ePUAP platform.

The notification form is available on the Ministry of Finance’s website: https://www.podatki.gov.pl/e-deklaracje/inne/pozostale-interaktywne#CBC-R

If you have any questions or concerns regarding the fulfillment of this obligation, we encourage you to contact us.

4o mini
Anna Skórska, Transfer Pricing Coordinator, ATA Tax Sp. z o.o.
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