CbC-P 2026: who is required to report?

In accordance with OECD guidelines on the automatic exchange of tax information, multinational enterprise groups are required to report their organizational structure and financial results on a jurisdictional basis. The purpose of this requirement is to increase transparency in tax settlements and to counteract aggressive tax optimization practices. The deadline for submitting the CbC-P notification for 2025 to the Head of the National Revenue Administration is 31 March 2026 (for entities whose financial year coincides with the calendar year).

What is CbC-P reporting?

The main objective of implementing Country-by-Country (CbC) reporting is to enhance the tax transparency of multinational enterprise groups and to limit aggressive tax optimization practices. This instrument is an important tool for tax authorities, enabling effective risk assessment in the area of transfer pricing.

CbC reporting makes it possible, in particular, to identify cases of artificial profit shifting to low-tax jurisdictions, assess whether a group’s tax structure is aligned with its actual economic activity, and conduct an in-depth analysis of global value chains operating within multinational enterprise groups.

Who is required to submit the CbC-P notification?

The reporting obligation applies to entities that are part of multinational enterprise groups but do not act as the reporting entity. It arises when the group’s consolidated revenues in the previous financial year exceed the specified thresholds, i.e.:

PLN 3.25 billion – if the consolidated financial statements are prepared in Polish zloty, or
EUR 750 million (or the equivalent in another currency) – if the consolidated financial statements are prepared in a currency other than PLN.

What data is reported in CbC-P?

In the notification, the entity belonging to a capital group is required to report the reporting entity (including its identification details) and the country or territory where the Country-by-Country report (CbC-R) for the group will be submitted.

When must the CbC-P notification for 2025 be submitted?

The CbC-P notification must be submitted within 3 months after the end of the group’s financial year. For entities whose financial year corresponds to the calendar year, the deadline is 31 March 2026.

CbC-R – the main report

As a rule, the obligation to prepare and submit the CbC-R report rests with the ultimate parent entity of the capital group that meets the criteria specified in the applicable regulations, in its country of tax residence.

The report must be submitted within 12 months after the end of the reporting financial year of the group. For groups whose financial year coincides with the calendar year (i.e. ends on 31 December 2025), the final deadline for submitting the CbC-R report is 31 December 2026.

How to submit CbC-P and CbC-R?

The CbC-P notification and the CbC-R report must be submitted electronically via the e-Declarations system. After submission, it is advisable to download the Official Receipt Confirmation (UPO) as proof of filing.

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