by Agnieszka PlucińskaKBZ Tax Alert: CbC-P Notification for FY 2025 — obligations and deadlines in 2026
An important compliance deadline is approaching for entities belonging to multinational enterprise (MNE) groups. Entities whose financial year corresponds to the calendar year (1 January – 31 December 2025) are required to submit the CbC-P notification for FY 2025 to the Head of the Polish National Revenue Administration (KAS) by 31 March 2026.
Failure to comply with this obligation may expose taxpayers to administrative penalties of up to PLN 1 million.
What is the CbC-P notification?
The CbC-P notification forms part of the Country-by-Country (CbC) reporting framework, introduced under the OECD BEPS initiative to enhance transparency regarding the global allocation of income, taxes and economic activity within multinational enterprise groups.
The CbC-P notification allows tax authorities to determine:
- which entity within the group submits the CbC report (CbC-R); and
- the jurisdiction in which the report will be filed.
The notification must be submitted by all Polish constituent entities of an MNE group, including both the reporting entity and non-reporting entities belonging to the group.
In 2026, the rules governing CbC-P notifications remain unchanged. However, large multinational groups will for the first time also be required to prepare a public Country-by-Country report. The public CbC report will be made available in the commercial register and on the company’s website, with the first reports covering FY 2025 to be published by 31 December 2026.Importantly, the new public reporting requirement does not replace the existing obligations related to CbC-R or CbC-P filings.
Who is required to submit a CbC-P notification?
The CbC-P notification must be submitted by entities that are members of multinational groups subject to CbC-R reporting but are not themselves the reporting entity (i.e. neither the ultimate parent entity nor a designated surrogate reporting entity).
The obligation arises where, in the preceding financial year, the consolidated group revenue exceeded:
- PLN 3.25 billion – where the consolidated financial statements are prepared in PLN; or
- EUR 750 million, or the equivalent of this amount in another currency.
What information must be included in the CbC-P notification?
The CbC-P form is relatively straightforward. A constituent entity is required to indicate:
- The reporting entity for the entire group (typically the ultimate parent entity or a designated reporting entity), together with its identification details.
- The jurisdiction (country or territory) where the CbC report (CbC-R) will be filed.
Filing deadlines
The notification must be submitted within three months after the end of the group’s financial year.
For groups whose financial year coincided with the calendar year (1 January – 31 December 2025), the filing deadline is 31 March 2026.
How should the notification be submitted?
The CbC-P notification must be submitted electronically:
- via the e-Declarations system, or
- through the e-Tax Office (e-Urząd Skarbowy) platform.
The official CbC-P form is published by the Polish Ministry of Finance,
Consequences of non-compliance
Failure to submit the CbC-P notification, or submitting it with incorrect or incomplete information, may result in an administrative monetary penalty of up to PLN 1 million.
Although the form itself is relatively simple, in practice certain issues may raise interpretative doubts, including:
- identification of the ultimate parent entity in the case of group reorganisations,
- determining whether the group revenue threshold triggering the CbC obligation has been exceeded,
- filing obligations of Polish branches of foreign enterprises operating in Poland,
- obligations within a Polish Tax Capital Group (PGK) – whether the notification should be submitted by the PGK as a whole or by each member individually,
- situations where an entity belongs to more than one capital group.
Our support
If you have any questions regarding:
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determining which entities within the group are required to submit a CbC-P notification,
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proper identification of the reporting entity,
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completing the notification in complex or non-standard situations (e.g. reorganisations, PGKs, foreign branches),
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preparing for the new obligation to publish a public Country-by-Country report,
our tax advisors will be pleased to assist you.
We can support you in assessing your reporting obligations, mitigating the risk of penalties and ensuring timely compliance with CbC requirements.
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