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CbC Notification - Note the upcoming deadline

2024-03-27

This is the last call to fulfil one of the reporting obligations in the field of transfer pricing – i.e. the submission of the CbC-P notification, i.e. the notification concerning the obligation to submit information on a group of entities.

Subjective Scope

Entities that are part of an international corporate group are under an obligation to submit a CbC-P notification if their results are consolidated in the group's financial statement, and the group's consolidated revenues in the previous financial year exceeded PLN 3,250,000,000 (where the group prepares consolidated financial statements in PLN) or EUR 750,000,000 or an equivalent of the amount (in other cases).

In this case, the taxpayer must notify the Head of the National Tax Administration that:

  • It is the parent entity, designated entity or another entity filing the information for the whole group (CbC-R), or
  • It names the reporting entity and the country or territory where the CbC-R report will be filed.

Deadline for Complying with the Obligation

The CbC-P notification must be submitted within 3 months of the end of the reporting financial year of the group of entities. Therefore, if the accounting year coincides with the calendar year, the deadline for filing the CbC-P for 2023 is April 2, 2024.

How to File

The CbC-P notification can only be submitted electronically via the e-Declaration system. One cannot send it via the ePUAP platform.

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

Should you have any questions or queries regarding the fulfilment of the above obligation, please do not hesitate to contact us.

 

 

Anna Skórska, Tax Manager (Transfer Pricing), ATA Tax Sp. z o.o.

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