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Tax

Review of CFC obligations and international reporting (CFC, CbC)

For businesses and groups operating internationally or holding shares in foreign entities who want to verify whether they meet all their reporting obligations.

Fee
from 2 300 EUR net
Prices are net, in EUR. VAT depends on your status and place of establishment.

You can order this service directly, without a prior consultation. We confirm the scope and the fee before we start.

Request a quote Book a consultation first
A consultation is optional. To discuss your matter with a lawyer first, you can book a consultation for PLN 600 net + VAT. If you then order the work, its cost is credited against the project fee.

Before we start, we agree and confirm the scope and the fee. The price is indicative and does not constitute an offer within the meaning of the Polish Civil Code.

What it includes

  • Analysis of the company structure and of its related entities
  • Assessment of the reporting obligation for controlled foreign companies (CFC)
  • Verification of country-by-country (CbC) reporting requirements for groups
  • Review of the deadlines and the form of reporting, including the notification and the group information
  • A report setting out a map of the obligations together with recommendations

What the price does not include

  • Preparation of the CFC, CbC or CBCR reports themselves (quoted separately)
  • Representation in an audit procedure
  • Analysis of tax consequences in individual jurisdictions

What you receive

  • A complete map of the CFC and CbC reporting obligations arising from the group structure
  • A report with recommendations on how the obligations can be met
How it works

How the review of CFC and CbC obligations proceeds

The review maps the group structure and identifies which reporting obligations follow from the shareholdings held and the operating activities. Five stages.

  1. Structure mapping

    We collect information on the companies, their locations, the shareholding structure and the type of activity carried out.

  2. CFC identification

    We analyse whether the group structure contains controlled foreign companies (CFC).

  3. CbC analysis

    We assess whether the group meets the criteria for country-by-country (CbC) reporting.

  4. Deadlines and form

    We review the deadlines and the form of reporting, including the notification and the filing of the group information.

  5. Report and recommendations

    We prepare a report with a map of the obligations and recommendations on reporting procedures.

What the review answers

An international structure generates reporting obligations that do not follow from turnover alone but from the shareholdings held, the control exercised and the place where activity is carried out. The review establishes which of those obligations apply to the group, in what form and by which deadline, and separates the ones already being met from the ones that have been missed. The result is a map of obligations rather than a set of filings, so that the group knows where the gaps are before an authority asks.

What is examined

We begin with the group chart and the list of related entities, the information on the countries of activity and the shareholdings held, and the documents on the reporting done so far for the period under review. Against that material we examine whether controlled foreign companies are present in the structure, whether the group meets the criteria for country-by-country reporting, and what the notification and the group information require. Where the documentation leaves gaps, the report states what it does not resolve.

Scope and fee

The price is quoted from EUR 2300 net and depends on the number of jurisdictions involved, the complexity of the group structure and the period covered. Preparing the reports themselves is quoted separately, as is representation in an audit procedure and analysis of the tax consequences arising in individual jurisdictions. The scope, the materials needed and the timetable are agreed before the work starts.

What the fee depends on

  • Number of jurisdictions in which the group operates or holds shares
  • Complexity of the group structure
  • Period covered by the review

We agree the fee individually, at an hourly rate or as a flat fee, and confirm it before we start.

Request a quote

To order this service, describe your matter. A consultation is not required. We confirm the scope and the fee before we start.

Information you share in connection with legal assistance is covered by the professional secrecy of advocates and attorneys-at-law under Polish law.

How to start

You can order this service directly or book a consultation first. A consultation is not required to order the service.

Book a consultationContact us