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.
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.
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:
© 2018 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.
The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.