| 24 February, 2023

The CbC reporting period is drawing closer

County-by-Country reporting (CbC) is yet another tool aimed at limiting tax abuse with respect to transfer pricing. Within the CbC framework, large groups of companies are obligated to notify tax authorities of their places of business, subsidiaries, and foreign establishments of the group, among other things.

Subject to CbC reporting are groups of companies whose consolidated revenues in the previous financial year exceeded:

  • PLN 3,250,000,000.00 - if the group of companies prepares its consolidated financial statements in PLN,
  • EUR 750,000,000.00 or an equivalent of this amount - in all other cases.

Two types of CbC reports can be distinguished depending on the entity’s status: the CbC-P report is submitted by an entity whose results fall under the consolidation of a group subject to CbC reporting, whereas the CbC-R report is submitted by the parent entity of such a group (or other designated entity).

Status of the entity

Type of form

Scope of data provided 

Submission period 

  • An entity belonging to a group of companies, which has its registered office or management board in Poland, or a foreign entity conducting business in Poland through a permanent establishment (e.g., a branch of a foreign entity).


The report should include, among other things, the identification data of the entity that will submit the information about the group.

Within 3 months of the end of the reporting financial year of the group (by 31 March 2023*)

  • The parent entity of the group (or designated entity) whose registered office or management board is located in Poland.


The report should contain, among other things, information on the entities that belong to the group.

Within 12 months of the end of the reporting financial year.

(by 31 December 2023*)

*in the event the reporting year coincides with the calendar year

Please note that the CbC-P and CbC-R forms can be submitted only via electronic means.

Failure to comply with the CbC reporting obligations may result in severe sanctions - the Head of the National Revenue Administration (KAS) may impose a fine of up to PLN 1,000,000.00. It should also be noted that submitting a report that is inconsistent with the data at hand or in an incomplete form is subject to sanctions as well.

Should you have any additional questions relating to CbC reporting, please contact TIAS Tax Department at: office@tias.pl.

O autorze

Anna Czyż