Poland: Transfer pricing, country-by-country reporting | KPMG Global
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Poland: Transfer pricing, country-by-country reporting exchange of information

Poland: Transfer pricing, country-by-country reporting

New legislation concerning the exchange of tax information with other countries was signed by the president on 20 March 2017. The new law imposes on entities belonging to large multinational corporations an obligation to indicate to the tax administration which unit from the group (and which country) submits the country-by-country (CbC) report. The law also clarifies the rules of the exchange of tax information between different countries.


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CbC reporting requirements

Entities belonging to groups that are subject to the requirement to submit the CbC report have a duty to indicate the reporting entity of the group. The new rules also introduced provisions that the requirement to submit the CbC report lies with the entity of the group, rather than the ultimate parent entity.

Exchange of tax information between different countries

The legislation introduces new and clarifying rules regarding the exchange of information regarding income, the exchange of information on accounts reported by financial institutions, and the exchange of information concerning tax interpretations, securing tax opinions, and decisions regarding arrangements for fixing transaction prices (such as advanced pricing agreements (APAs)).


Read a March 2017 report [PDF 384 KB] prepared by the KPMG member firm in Poland


Details of the measures include:

  • Transfer of regulation regarding CbC reporting
  • CbC reporting obligations
  • Obligation of groups whose ultimate parent entity has its registered office or management board abroad
  • Automatic exchange of information about groups of entities
  • Notification obligations in the scope of CbC reporting
  • Penalties
  • Automatic exchange of information on tax interpretations and decisions regarding transfer (transaction) prices

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