NOTE: valid duties until 2 April

Transfer pricing

As early as 2 April 2024, the deadline for filing Form CBC-P for 2023 (when the group’s financial year is the same as the calendar year) will pass.

The need to file the CBC-P form will arise when the consolidated revenues of the group in the previous financial year exceeded PLN 3.25 billion (in the case of a consolidated statement in PLN) or EUR 750 million or the equivalent amount (in other cases).

As a reminder, the CBC-P notification must be submitted electronically on a web-based form.

Reporting of tax schemes

The deadline for filing the corporate income tax return is approaching, which coincides with the deadline for filing the so-called MDR secondary information on tax schemes (MDR-3 information).

We would like to point out that if the Company in 2023 performed any activities that are part of the tax scheme / obtained a tax benefit resulting from the implementation of the tax scheme, it is obliged to file the so-called secondary information on the tax scheme by the deadline of the tax return to which the tax scheme related.

Accordingly, tax schemes relating to the Company’s 2023 corporate income tax returns should, in principle, be reported secondarily by 2 April 2024.

Simply filling in the MDR-3 forms is cumbersome in practice. At the same time, in this respect, it is worth ensuring that a given scheme is reported correctly, and at the same time in a manner limiting unnecessary doubts of tax authorities. In fact, it should be borne in mind that approximately 100 audits of taxpayers’ settlements have already been initiated recently as a result of submitted reports on tax schemes.

From our side, we are available to support you in preparing the relevant MDR information.

At the same time, we offer support in the form of a comprehensive MDR review also covering previous accounting periods, aimed at verifying the correctness of the Company’s compliance with its obligation to report MDR tax schemes.

Reporting by real estate companies

Once again this year, real estate companies and their shareholders must file special information for 2023 with the tax authorities. The deadline for filing the information is 2 April 2024.

The key here is to identify the entities covered by the reporting obligation and, in particular, to identify the entities that meet the definition of a real estate company.

In the case of international groups, the reporting obligation may extend to foreign entities.

Note that for practical reasons, reporting may require foreign entities to obtain a TIN.

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We encourage you to analyse as soon as possible whether and which of the above-mentioned obligations need to be fulfilled in the near future. Of course, we also encourage you to make use of our assistance in this regard!