Public country-by-country reporting (CbCR) is moving from regulatory implementation to practical application. For many multinational groups, financial years beginning after June 21 2024 – in practice, FY 2025 for calendar-year groups – are the first periods for which a report on income tax must be prepared and made public.
In Poland, companies in international groups are now focusing on a number of practical implementation challenges, including:
Process ownership and governance;
Reliable data sources and reconciliation with group reporting;
Explanations of the figures; and
Treatment of commercially sensitive information, including the application of the safeguard clause.
These questions make public CbCR more than a tax compliance exercise. It requires coordination across tax, finance, legal, and group reporting functions. Early experience in Poland suggests that clear responsibility for each stage is one of the main operational challenges, particularly where the ultimate parent company is outside the European Economic Area (EEA).
Implementation is not only a tax project
Responsibility for public CbCR should be agreed early. Although the reporting obligation is tax-driven, preparing the report often requires collecting and reconciling information from multiple entities across the group and from different jurisdictions. In practice, this means that the process should be coordinated at group level, with a common data request and consistent definitions used by all relevant entities. The challenge is therefore not only technical but also organisational, requiring a clear allocation of responsibilities, efficient information flows, and early alignment on what data will be collected, by whom, and in what format.
This can create uncertainty. Polish subsidiaries may wait for instructions from headquarters, while headquarters may expect local entities to verify or publish information. The challenge can be greater where a group has several entities on the same market and it is unclear which should coordinate the process. Clear ownership of key tasks, supported by an internal timetable and escalation path, can reduce this risk.
This is particularly important because public CbCR is an EEA-driven obligation. The key questions are which entity will publish the report, how the information will be made available, and which group entities, if any, will need to support the process. Under the EU framework and Polish implementing rules, a Polish subsidiary may have publication obligations in certain circumstances, including where the required report is not made available by the ultimate parent. These scenarios should be addressed before the reporting deadline.
Data consistency: a key challenge
Another recurring issue is consistency between reporting datasets. Public CbCR figures may need to be compared with statutory financial statements, corporate income tax settlements, transfer pricing documentation, and other tax disclosures.
Differences will not automatically indicate an error. They may result from accounting standards, consolidation adjustments, timing differences, tax incentives, or the way employees and revenues are allocated between jurisdictions.
Lessons from the Polish market
Experience from Polish implementation projects suggests that companies benefit from testing the process before the first publication deadline. A dry run can identify missing data, unclear definitions, differences between local and group approaches, and figures that may require additional explanation.
Polish entities should also assess whether any information in the public country-by-country report could qualify for temporary omission under the safeguard clause. Polish law allows specific information to be omitted where disclosure could seriously prejudice the market position of the reporting undertaking, subject to the statutory conditions. The rules should be reviewed carefully before use, particularly for groups operating across several jurisdictions, because requirements may differ between countries.
Good practices before publication
Multinational groups should consider the following practical steps:
Confirm which EEA entity will be responsible for reporting and publication, and whether the Polish entity has a local publication or support role;
Agree ownership between tax, finance, legal, and group reporting teams, including the communication flow;
Establish a timetable covering data collection, review, approval, and publication;
Perform a dry run using FY 2025 data or appropriate prior-year information;
Reconcile figures with financial statements, tax returns, and transfer pricing documentation; and
Prepare a concise explanation of key Polish figures and any sensitive areas.
From compliance to readiness
Public CbCR should be integrated into the group’s reporting processes rather than treated as a standalone tax filing. The Polish experience indicates that early preparation, clear responsibilities, and data testing can reduce the risk of last-minute issues.
For Polish companies that are part of international groups, preparation should cover both the report and the supporting analysis. Companies should be able to clearly explain how the figures were produced, why they may differ from other reporting datasets, and which entity is responsible for publication.
