
Public CbC-R – first reports for the 2025 financial year
Public CbC-R will apply for the first time to 2025. The largest corporate groups must prepare for new obligations and public disclosures.
We will prepare transfer pricing analyses (benchmarking / compliance analyses) to help you determine or verify the arm’s length level of remuneration for various types of intra-group transactions (services, goods, financial, licensing, etc.).
You can be sure of the high-quality of our benchmarks because:
Our qualitative analyzes will make you feel secure when signing and filing the statement on the preparation of transfer pricing documentation and the arm’s length nature of prices applied between related entities.
| Goods and service transactions | Simplified option | Standard option | Extended option | Extended option + COVID-19 impact / current economic situation |
| Assumptions for the review of arm’s length remuneration | Automatic data selection | Automatic and additionally a manual review of data on websites | Automatic and additionally a manual review of data on websites, including the recommended point from the range | Automatic and additionally a manual review of data on websites, including the recommended point from the range as well as the COVID-19 impact taken into account |
| Databases | External databases – Polish and European | External databases – Polish and European | External databases – Polish and European | External databases – Polish and European as well as publicly available data on the impact of COVID-19 |
| Outcome of works | Benchmarking report compliant with Polish tax regulations | Benchmarking report compliant with Polish tax regulations | Benchmarking report compliant with Polish tax regulations including the recommended point from the range | Benchmarking report compliant with Polish tax regulations including the recommended point from the range as well as conclusions from the COVID-19 impact analysis |
| Individual selection strategy | √ | √ | √ | √ |
| Automatic data selection | √ | √ | √ | √ |
| Additional manual data refinement | √ | √ | √ | |
| Additional calculations / adjustments to financial analysis | √ | √ | √ | |
| Indicating a recommended point from the range | √ | √ | ||
| COVID-19 impact analysis | √ | |||
| Support from MDDP experts | 2 h | 4 h | 4 h | 6 h |

Partner | Tax adviser | Head of the Transfer Pricing Practice E: magdalena.marciniak@mddp.pl T: (+48) 665 746 360

Partner E: magdalena.dymkowska@mddp.pl T: (+48) 501 108 261

Partner E: agnieszka.krzyzaniak@mddp.pl T: (+48) (22) 322 68 88

Senior Manager E: marta.klepacz@mddp.pl T: (+48) 533 889 036

Senior Manager E: adrian.mroziewski@mddp.pl T: (+48) 505 294 041

Manager E: jakub.patalas@mddp.pl T: (+48) (22) 322 68 88

Manager E: agnieszka.walska@mddp.pl T: (+48) (22) 376 52 86

Public CbC-R will apply for the first time to 2025. The largest corporate groups must prepare for new obligations and public disclosures.

The exemption from transfer pricing analysis in the first year of business raises doubts. Can a new entity benefit from this simplification?

A draft amendment to the PIT Act, the CIT Act and the Act on Lump-Sum Income Tax (No. UD461) has been published in the Council of Ministers’ legislative work register. The two main proposals are to extend the robotisation tax relief for another 10 years and to abolish the expansion tax relief.