CBC and CBC-P reporting obligation

Country-by-Country Reporting (CBC) has been used in Poland for several years as a tool for exchanging tax information between administrations in different countries. Until now, however, this data has remained inaccessible to the public. This is changing – Poland has implemented a directive introducing a new obligation to submit a so-called public CBC report (public CBC).

CBC-R and CBC-P – exchange of information between authorities

The CBC reporting obligation applies to international capital groups whose consolidated revenues exceed EUR 750 million (PLN 3.25 billion if the consolidated financial statements are prepared in PLN).

Until now, the reporting system consisted of two documents. The first is the CBC-R – a detailed summary containing information on the global distribution of income, income tax paid, employment, and other group data. The CBC-R is generally filed by the group’s parent entity in its country of residence within 12 months of the end of the reporting financial year.

The CBC-R is supplemented by the CBC-P, a notification submitted by entities belonging to capital groups subject to the reporting obligation. The notification contains information about the reporting entity and indicates the country in which the CBC-R will be filed. The CBC-P must be filed within three months of the end of the group’s reporting financial year (in the case of a calendar financial year, the deadline is the end of March 2026 ).

Important: These reports are not public. Both the CBC-P and CBC-R are available only to tax authorities.

CBC Public Report – A New Era of Transparency

Directive 2021/2101 imposed a new obligation for public country-by-country reporting. In Poland, these provisions were implemented through an amendment to the Accounting Act (Act). As a result, data previously available only to tax authorities is now publicly available for the first time.

The CBC public report is an additional obligation and does not replace the existing CBC-R. Both reports operate in parallel, but differ in scope and data format.

Public CBC reporting generally applies to ultimate parent entities and independent entities based in Poland. The requirement to prepare, publish, and disclose an income tax report is based on exceeding the PLN 3.5 billion revenue threshold in the consolidated (or standalone, for independent entities) financial statements in each of the last two financial years.

Important: the obligation does not apply to groups in which both the parent company and all subsidiaries are based in Poland.

The obligation to publish and make available the report may also apply to, among others, a Polish subsidiary that:

• does not have the status of a micro or small entity within the meaning of the Act on the Regulation of the Republic of Poland, and
• belongs to an international group whose parent company is based outside the EEA and whose consolidated revenues of the parent company exceeded EUR 750 million in each of the last two years.

Moreover, if the income tax report is not published by the parent company (or a standalone entity), the obligation to prepare a public report also “passes” to the Polish company. Therefore, Polish entities must monitor whether they have not fulfilled this obligation.

In Poland, in the event of an obligation to report income tax, the Act imposes the following obligations on companies:

• submitting an income tax report to the relevant court register;
• posting the report on the entity’s website;
• ensuring public access to the report on the entity’s website for a period of at least 5 years.

The first reports will cover the financial year starting after 21 June 2024. The publication deadline is 12 months from the balance sheet date, which for entities with a calendar financial year means publishing reports for 2025 by 31 December 2026.

Why is this important?

Many groups that previously reported CBC only to government offices will be required to prepare an additional report – this time also for public disclosure. Therefore, especially in the first year of reporting, it is worth reviewing the obligations related to the public CBC in advance. While the scope of data required in both reports (i.e., the CBC-R report and the report) is similar, it should be noted that the new report has a more standardized format, which will facilitate comparisons between such reports by various stakeholders.