Country-by-Country 2022 reporting - an important obligation coming soon

Country-by-Country - who is obliged to report?

The obligation to prepare the so-called Country-by-Country Report (CbC-R) shall lie with the entities that belong to capital groups whose consolidated revenues in the financial year exceeded:

1. PLN 3 250 million - in the case of capital groups preparing consolidated financial statements in Polish zloty (PLN),
2. EUR 750 million - or the equivalent of this amount converted according to:

a) the rules specified by the country or territory in which the parent company has its registered office or management board - in the case of a capital group whose parent company has its registered office or management board outside the territory of the Republic of Poland,

b) the last exchange rate published by the European Central Bank on the last day of the financial year preceding the reporting financial year - if:

• a capital group in which the parent company has its registered office or management board in the territory of the Republic of Poland, prepares consolidated financial statements in a currency other than PLN,
• the country or territory referred to in point (a) and, did not specify the rules for converting this amount.

Country-by-Country reporting - where and when to file a CbC-R report?

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.

CBC-R report shall be submitted within 12 months from the end of the financial year. 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 can be sent to the tax authority only by electronic means.

How can we help?

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