Country-by-Country 2025 reporting – an important obligation coming soon
CbC reporting obligation – who does it apply to?
Information about group of entities so called Country-by-Country Report
(CbC-R) shall be prepared by the entities which belong to capital groups whose consolidated revenues in the previous financial year exceeded;
- PLN 3 250 million - in the case of capital groups preparing consolidated financial statements in Polish zloty (PLN),
- EUR 750 million - or the equivalent of this amount converted according to:
- The rules specified by the country or territory in which the parent company has its registered office or management board - in the case of a capital group whose parent company has its registered office or management board outside the territory of the Republic of Poland,
- The last exchange rate published by the European Central Bank on the last day of the financial year preceding the reporting financial year - if:
- a capital group in which the parent company has its registered office or management board in the territory of the Republic of Poland, prepares consolidated financial statements in a currency other than PLN,
- the country or territory referred to in point (a), did not specify the rules for converting this amount
The report should be submitted in the country of the parent company, however, the capital group may designate another entity from the group to submit a CbC-R in the country of its residence.
Companies which belong to the group of entities, are not a parent company, but have their seat or management in Poland or foreign entities having a branch in Poland are obliged to submit a notification to the Head of the National Tax Administration confirming that the company:
- Is a parent entity, a designated entity or other entity that provides information about a capital group – CbC-R, or
- Indicates the reporting company and the country where the information of the capital group will be filed – CbC-P.
CBC-R report shall be submitted within 12 months from the end of the financial year.
The CbC-P notification shall be submitted within 3 months from the end of the financial year.
Both the CbC-R report and the CbC-P notification can be sent to the tax authority only by electronic means.
New CbC public reporting regulations – what's changing?
In accordance with EU Directive 2021/2101, the regulations on public CbC reporting came into force in June 2024. In Poland, the new regulations on public CbC reporting were implemented in the Accounting Act (art. 63l.- 63o.).
The new regulations do not abolish the existing CbC reporting obligations submitted to the Head of KAS but only extend them by requiring public CbC reporting.
According to the new provisions, international groups operating, through their parent companies, subsidiaries or branches, will be required to publicly disclose information on income tax paid and other tax details.
The obligation to report income tax for the financial year applies to ultimate parent companies or stand-alone entities whose revenues, resulting from the consolidated or stand-alone financial statements respectively for each of the last two financial years, exceed the thresholds:
- PLN 3,500 million - in the case of groups with an EU-based ultimate parent company (or in the case of stand-alone entities),
- EUR 750 million - in the case of groups with an ultimate parent company (or in the case of stand-alone entities) based outside the EU.
Groups that operate solely in Poland, with no presence abroad, are exempt from public reporting of the CbC-R.
Entities subject to the CbC public reporting obligation must report to the publicly accessible commercial register (KRS) and publish the reports on their websites. The report should be available on the entity's website for at least 5 years.
The first report will cover the year 2025 and should be published within 12 months of the balance sheet date - so for companies which have a fiscal year that corresponds to the calendar year, publication will have to take place by December 31, 2026.
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