crowe-Country-by-Country  reporting for 2019-sky

Country-by-Country  reporting for 2019

crowe-Country-by-Country  reporting for 2019-sky
The Act of 9 March 2017 on exchange of tax information with other countries (uniform text of 15 March 2019, JoL of 2019, item 648) imposes an obligation on entities belonging to international capital groups to automatically exchange tax information, i.e. to apply the CbC reporting mechanism.

Which entities are obliged to submit CBC-R reports and which are required to submit a CBC-P notification?

Entities being part of capital groups whose consolidated revenues in the financial year exceeded

  1. PLN 3.25 billion - in case of capital groups preparing consolidated financial statements in PLN,
  2. EUR 750 million - in case when a capital group, in which the parent company has its registered office or management in Poland, prepares consolidated financial statements in currencies other than PLN,

are obliged to prepare so called Country-by-Country Report (CbC-R).

The report should be submitted in the country of the parent company, however, the capital group may designate another entity from the group to submit a CbC-R in the country of its residence.

Companies having their seat or management in Poland or foreign entities having a branch in Poland are obliged to submit a notification to the Head of the National Tax Administration confirming that the company:

  1. is a parent entity, a designated entity or other entity that provides information about a capital group – CbC-R or
  2. indicates the reporting company and the country where the information of the capital group will be filed – CbC-P.

What is the deadline for submitting the requested information?

The CBC-R report shall be submitted within 12 months from the end of the financial year whereas the  CbC-P notification shall be submitted within 3 months of the end of the financial year.

Both the CbC-R report and the CbC-P notification should be filed by electronic means only.

Should you need our assistance in respect of the reports or notifications, we will be happy to help. In case of additional questions please feel free to contact us.

[email protected]  

Contact our expert

Agata Nieżychowska
Agata Nieżychowska
Tax Director

Tax advisory