Tax deadlines for closing the 2023 financial year

Closing the accounts for a given financial year is a complex process, involving many activities ranging from taking inventory, confirming balances with counterparties and the bank, establishing required reserves and write-downs, doing balance sheet valuations, and preparing the annual financial statements and tax returns. Most of these activities are internal and are not burdened by specific statutory deadlines. However, accounting and tax regulations contain rigid deadlines within which each entity must complete the accounting and tax closing process.

Deadlines for closing the 2023 financial year

In addition to the stage of preparing the final financial figures, the process of closing the books for the fiscal year includes financial reporting, where the annual financial statements are prepared, and tax reporting, where the tax return is prepared and other reporting obligations are fulfilled.

Below are the main deadlines for the tax closing of 2023, along with a detailed discussion of each step.

Activity	Deadline to*
Accounting
Closure of the accounting books	31 March 2024
Preparation of annual financial statements	31 March 2024
Tax
CIT tax return	2 April 2024
Information IFT-2R	2 April 2024
CIT-N1 and PIT-N1 information by real estate companies	2 April 2024
Country-by-Country Reporting	2 April 2024
Information ORD-U	2 April 2024
Corporate
Report on activities	31 March 2024
Approval of financial statements	30 June 2024
Submission of financial statements and other documents	15 July 2024

(*) For entities whose financial year is the calendar year.

Financial year in the Polish legal system and the rules of it’s change

CIT tax return

Corporate income taxpayers shall file the CIT-8 tax return by the end of the 3rd month of the following fiscal year. For entities whose fiscal year is the calendar year, this means that the filing of the CIT-8 return for 2023 must be done by March 31, 2024, but due to the Easter holiday, they can do so no later than April 2, 2024.

Unlike last year, when the deadline for filing the return was pushed back by three months (to June 30), this year the Finance Ministry has announced that there will be no extension of the deadline for filing the return.

In order to prepare the CIT-8 return, the taxpayer must prepare an appropriate tax calculation based on data from the books of account. Depending on the specific nature of the entity, accounting income and expenses must be adjusted accordingly for non-tax items, required tax adjustments (e.g., tax depreciation) must be made, and appropriate tax categories covered by tax limits (e.g., debt financing cost limit) must be calculated. If the taxpayer received income (revenue) from a source of capital gains, the tax calculation must include a breakdown of tax income and expenses into the appropriate sources.

Capital gains. Separate source of income

The tax income calculated in this way, within the relevant source of income, can be reduced (according to certain rules) by tax losses from previous years.

Submission of the CIT-8 return is possible only electronically. For this purpose, the person filing the return must register an appropriate power of attorney in advance with the tax authority. Sending of the return is carried out through the e-Deklaracje gateway, including with the use of programs that have a plug-in that allows the return to be sent to this gateway.

Reduced CIT rate. Revenue limits in 2023 and 2024

Information IFT-2R

Form IFT-2R is information on the amount of income/revenue earned by non-residents, i.e. corporate income taxpayers whose registered office or management is not located in Poland.

The correct fulfillment of this obligation is closely related to the subject of withholding tax. This is because this form should be filed both in the case of payments of dues (as defined in Articles 21 and 22 of the CIT Law) to foreign entities, and in the case when withholding tax has not been collected (e.g., a tax exemption is applied) or has been paid according to preferential rules (e.g., a reduced tax rate resulting from a double tax treaty). In order to apply the exemption or reduced withholding tax rate resulting from the relevant double tax treaty, it is extremely important to duly verify the actual recipient of the payment and to obtain a tax residency certificate from the foreign counterparty.

The IFT-2R must be filed by the end of the third month of the year following the tax year in which the payments were made. For payers whose fiscal year is a calendar year, this means that the filing of the IFT-2R information return for 2023 must be done by March 31, 2024, but due to the Easter holiday, they can do so no later than April 2, 2024.

The IFT-2R information must be filed with the Lublin Tax Office, separately for each recipient of the receivables.

CIT-N1 and PIT-N1 information by real estate companies

Real estate companies (hereinafter “ReCo”) are required to provide information on their ownership structure to tax authorities by the end of March 2024. This obligation also applies to their shareholders, including foreign entities that are not taxpayers in Poland.

Reporting of ownership structure in ReCo companies should be done on forms:

CIT-N1/ PIT-N1 – information filed by the real estate company about its shareholders,

CIT-N2/ PIT-N2 – information filed by a shareholder about the rights held in a real estate company.

As a rule, for the correct filing of the form, you need a Tax Identification Number (or Pesel in the case of individuals). The completed declaration should be submitted electronically to the appropriate tax office.
The information must be sent by the end of the third month after the end of the tax year of the real estate company (or the fiscal year of the company, if it is not a taxpayer). For most entities, the deadline for submitting the relevant forms is the end of March 2024, with the final deadline this year being Tuesday, April 2, 2024, due to the Easter holiday.

Reporting by real estate companies for 2023

Country-by-Country Reporting

Entities that are part of a group of entities with consolidated revenues of more than €750 million by March 31, 2024 file a CbC-P notification for 2023. Parent company or other designated entity submits CbC-R entity group information for 2023 by December 31, 2024.

Any entity that is part of a group of entities is required to report CbC if its results are consolidated in the group’s financial statements and the group’s consolidated revenues in the previous fiscal year exceeded:

PLN 3,250,000,000 if the group prepares consolidated financial statements in PLN, or

EUR 750 million or the equivalent of this amount, converted according to the rules indicated in the Tax Information Exchange Act.

If the indicated revenue level is exceeded, the entity shall notify that:

is itself the parent entity or the entity designated to prepare and file group information for the entire group of entities (CbC-R), or

is an entity belonging to a group required to file a CbC-R report and in its CbC-P notification indicates the reporting entity and the country or territory where the CbC-R report will be filed.

The deadline for CbC-P reporting is 3 months after the end of the previous fiscal year. If the group’s reporting year follows the calendar year, the deadline for filing the CbC-P notification for 2023 is March 31, 2024, with the deadline for this year being Tuesday, April 2, 2024, due to the Easter holiday.

The designated entity has 12 months from the end of the previous financial year to prepare and submit the CbC-R.

There is a penalty of up to PLN 1 million for failing to comply with the reporting or country-by-country notification obligation, or for submitting incomplete or inconsistent reporting.

Country-by-Country reporting for 2023

Information ORD-U

Form ORD-U is the information that is submitted by entities that have entered into contracts with non-residents within the meaning of the foreign exchange law in a given year.

This information shall be prepared and submitted to the tax authority if:

one of the parties to this agreement, directly or indirectly, participates in the management or control of the other party to the agreement or holds an interest in its capital entitling it to at least 5% of all voting rights, or

another entity, which is not a party to the agreement, simultaneously participates, directly or indirectly, in the management or control of the entities that are parties to the agreement, or holds shares in the capitals of such entities entitling, in each of them, to at least 5% of all voting rights.

In the above-mentioned cases, the ORD-U information takes into account agreements that were concluded in the tax year with the same non-resident, and the sum of receivables or the sum of liabilities arising from these agreements exceeded the equivalent of EUR 300,000.

If, on the other hand, the non-resident who is a party to the agreement has an enterprise, branch or representative office in the territory of the Republic of Poland within the meaning of separate regulations, the ORD-U information shall include agreements in which the one-time value of receivables or liabilities exceeded the equivalent of EUR 5,000.

The information shall be prepared for the tax year and sent to the head of the tax office within eleven months, counting from the end of that tax year. For entities whose fiscal year is a calendar year, this means that the filing of the IFT-2R information return for 2023 must be done by November 30, 2024, and due to the fact that the day this year falls on a Saturday, they can do so no later than December 2, 2024.

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