We would like to remind you that March 31 of this year is the deadline for filing the notification regarding the obligation to provide information on the group of entities (CBC-P) for taxpayers whose fiscal year coincides with the calendar year.

This is because according to Article 86(1) of the Act of 9 March 2017 on exchange of tax information with other countries, the notification must be submitted within 3 months from the date of the end of the reporting fiscal year of the group of entities.

Each entity in a group of entities is required to file a CbC-P notification where its 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 (where the group prepares consolidated financial statements in PLN) or EUR 750 million or the equivalent of this amount, converted in accordance with the rules indicated in the Tax Information Exchange Act (in other cases). In such a situation, the entity notifies that:

(a) it is itself a parent entity or an entity designated to prepare and file group information for the entire group, or

(b) it is an entity in a group required to file a CbC-R Report and, in its CbC-P Notice, indicates the reporting entity and the country or territory in which the CbC-R Report will be filed.

Where the fiscal year covers a period other than 12 months, the threshold amount of consolidated revenues is to be set at 1/12 for each month of the fiscal year started.

Notification CbC-P should be submitted only electronically (via e-Deklaracje system).

The notification template is available at the following link: https://www.podatki.gov.pl/e-deklaracje/inne/pozostale-interaktywne/#CBC-P.

In the Notification CbC-P it is necessary to indicate identification data and the address of the notifying entity, and to specify whether the notifying entity will or will not be the entity submitting the information on the group of entities.

In the latter case, the identity and address of the reporting entity and the country in which the information on the group of entities will be transmitted should be indicated.

The deadline for the parent entity to meet the obligation to submit the CBC-R report is 12 months from the end of the reporting fiscal year.

For taxpayers with a fiscal year that coincides with the calendar year, the reporting deadline for 2020 will be December 31, 2021.

In case of failure to comply with the obligation to submit CBC-P notification or submission of CBC-P notification which is incomplete or inconsistent with the data held, the taxpayer may be fined up to PLN 1 million.


Author: Beata Rawa – Transfer Pricing Manager