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The implemented Act of 9 March 2017 on exchange of tax information with other countries introduced additional obligation of reporting for entities belonging to multinational groups, which have their registered or management seat located in Poland or conduct their business activity through permanent establishment in the territory of Poland.

According to the new regulations, entities enlisted above are obliged to submit a CBC notification to the Head of the National Revenue Administration concerning the information about the groupof entities (so called Country-by-Country report).

The obligation of submitting the CBC notification applies only to the entities being the part of the capital groups, which are subject to prepare and submit the CBC report in other countries or territories. Failure in submission of CBC notification may result in fine imposed bythe Head of the National Revenue Administration of value up to PLN 1 000 000.

The CBC notification includes information:

1)    Concerning the role of the entity in the group – whether it is a ultimate parent company, a designated entity or an entity submitting the information about the group,

2)    Indicating the entity from the capital group obliged to submit a CBC report together with an indication of the country or territory where the CBC report will be submitted.

During the transitional period the deadline for submission of the first CBC notification is 10 months from the last day of the financial year.

Transitional period applies to the financial year that began after 31st December 2015 but not later than before 1 January 2017.

As a result, entities which financial year began on 1 January 2016 and ended on 31 December 2016 are obliged to submit the CBC notification for FY 2016 by the end of October 2017.

The form of CBC notification in its draft version with the instruction is available on the Polish Ministry of Finance’s website. The final version of the CBC notification in the form of electronic document has not yet been published.


Whenever needed or if necessary, please contact us at:

Renata Dłuska   tel. + 48 22 322 68 80,

Magdalena Marciniak tel. + 48 22 322 68 84

or the Company’s MDDP advisory

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