MDR tax scheme reporting in 2021

Reporting of both cross-border and domestic tax schemes was introduced in Poland in 2019. In 2020, there was a need to report again the schemes with the so-called first activity taking place between 26 June 2018 and 30 June 2020. The year 2020, due to the COVID-19 pandemic, brought an extension of the deadline for these obligations until early 2021. Which companies and on what deadline must file MDR reports with National Revenue Administration (KAS)?

Re-reporting the cross-border tax schemes - what is the deadline?

The reporting suspension has come to an end and the deadlines for submitting information on tax schemes in the form of MDR-1, MDR-3 and MDR-4 files to the head of KAS expire in Q1 and Q2.  Since 1 January 2021, the standard reporting deadlines for cross-border schemes have been reintroduced.

MDR reporting - current deadlines for cross-border schemes:

• 31 January 2021 - the deadline for re-reporting the cross-border schemes (MDR-1 information) for beneficiaries,
• 28 February 2021 - deadline for re-reporting the cross-border schemes (MDR-1, MDR-2) for supporters (e.g.: auditors, accountants, financial institutions),
• 30 April 2021 - deadline for filing quarterly information on the provision of a standardised tax scheme (MDR-4). The obligation applies only to promoters (e.g.: a tax adviser, attorney at law or barrister), and supporters, and to information on the tax benefit/use of a tax scheme (MDR-3) relating to beneficiaries if, by 31 December 2020, the company as a beneficiary carried out any activities that were part of a cross-border tax scheme or obtained a tax benefit from such a scheme, unless the deadline expired before 30 June 2020 or expires after 30 April 2021.

The obligation to re-report applies to the entity which made the original notification.

Reporting of the domestic tax schemes - what is the deadline?

For domestic tax schemes, reporting deadlines remain suspended. According to the regulations, reporting deadlines do not commence and those commenced are subject to suspension from 31 March 2020 until the 30th day following the date of revocation of the state of epidemic hazard and state of epidemic declared in relation to COVID-19.

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