CbC-P Notification – deadline in 2025 and who must submit it

The deadline for submitting the CbC-P notification for 2024 to the Head of the National Revenue Administration (KAS) is fast approaching—31 March 2025 (for entities whose financial year aligns with the calendar year).

This obligation applies to entities that are part of corporate groups required to submit a Country-by-Country Report (CbC-R).

What is CbC-P reporting?

The CbC-P notification is a separate, supplementary form in which obligated entities provide the National Revenue Administration (KAS) with information about the entity within their group responsible for submitting the CbC-R.

Who is required to submit the CbC-P notification?

This obligation applies to entities (other than the reporting entity) that are part of corporate groups required to submit a CbC-R. It arises when the group’s consolidated revenue in the previous financial year exceeds:

• PLN 3.25 billion (for consolidated financial statements in PLN), or
• EUR 750 million or the equivalent amount in another currency.

What Information is reported in the CbC-P notification?

In the CbC-P notification, the entity within the corporate group must indicate the designated reporting entity, including its identification details, and specify the country or territory where the CbC-R will be submitted.

When must the CbC-P notification for 2024 be submitted?

The CbC-P notification must be submitted within three months of the end of the corporate group’s financial year.

For groups whose financial year ran from 1 January 2024 to 31 December 2024, the submission deadline is 31 March 2025.

How to submit the CbC-P notification?

Both CbC-P and CbC-R must be submitted electronically via the e-Deklaracje system. The CbC notification template is available on the Ministry of Finance website >> https://www.podatki.gov.pl/e-deklaracje/inne/pozostale-interaktywne#CBC-R

Penalties for non-compliance

Failure to submit the CbC-P notification, or submitting an incomplete or incorrect notification, may result in an administrative penalty of up to PLN 1 million.

The form itself is not complex, so completing it should not pose significant difficulties. However, in practice, taxpayers operating within corporate groups may face questions or uncertainties, such as:

1. Which entity should be indicated as the ultimate parent in the CbC-P notification if the parent entity changed during the year due to group restructuring?
2. How should the consolidated revenue threshold be determined to assess the obligation to submit the CbC-P notification?
3. Who is responsible for submitting the CbC-P notification if a foreign entity operates in Poland through a local branch?
4. In the case of a Tax Capital Group (PGK), should the CbC-P notification be submitted by:

• the PGK as a taxpayer,
• each entity individually, or
• both the PGK and each entity separately?

How should the CbC-P notification be completed if an entity belongs to two different foreign corporate groups?

Find out #MORE -> https://www.mddp.pl/transfer-pricing/