Selected taxpayers of the corporate income tax are subject to an obligation to prepare and publish information on the execution tax strategy for the tax year. The information covering 2020 should be prepared and published by 31 December 2021.


Whom does it concern?

The obligation applies to:

  • taxpayers whose revenues exceeded EUR 50 million in a tax year,
  • tax capital groups.


What does the information on the execution of tax strategy cover?

Taxpayers are required to prepare and disclose information on, inter alia:

  • approach to processes and procedures on managing obligations arising from tax regulations and ensuring their proper execution,
  • the number of submitted reports on tax schemes (MDR), separately for each tax,
  • transactions with related entities, the value of which exceeds 5% of the assets balance sheet total (based on the Statutory Financial Statements),
  • tax settlements in countries applying harmful tax competition,
  • restructuring activities planned or undertaken by the taxpayer,
  • submitted applications for a tax ruling, binding VAT rate information (WIS) and binding excise information (WIA),
  • voluntary forms of cooperation with the National Fiscal Administration authorities.

The above catalog is open and the information itself is to be prepared taking into account the nature, type and size of the business.

The regulations do not define what a tax strategy is and what procedures a taxpayer should have. To fulfill the above obligations, it may be necessary to refer to separate acts and regulations (e.g. the Guidelines on Tax Control Framework regarding cooperation with the Head of National Fiscal Administration under the Cooperative Compliance Program) as well as to indicate the manner of making decisions in tax matters and the persons involved (alternatively, organizational units).


How much time is there to prepare and publish the information on the execution of tax strategy?

Taxpayers have 12 months after the end of the tax year to publish the information on the execution of tax strategy on a website and submit relevant information to the tax office.


What are the sanctions for failure to comply with the obligation?

The entrepreneur may be fined up to PLN 250 000.


Our support

PwC experts have great experience gained during tax function assessment projects  using the Tax Management Maturity Model (T3M) which is based on OECD guidelines. We have also prepared a number of tax strategies and policies, also supporting clients in joining the Cooperative Compliance Program. 

We are ready to support you in fulfilling the new obligation in a way that will be aligned with your business strategy and the way your organization operates.