The end of March marks an important deadline for taxpayers subject to CIT, requiring them to fulfill various obligations related to the closing of the tax year.
One such obligation is the reporting of tax arrangements (MDR-3) concerning corporate income tax.
Entities required to report
In principle, the responsibility for submitting information on tax arrangements to the Head of the National Revenue Administration (Szef KAS) primarily rests with so-called promoters—entities that provide legal solutions qualifying as tax arrangements.
However, the obligation to submit the MDR-3 form applies exclusively to so-called beneficiaries—entities that have carried out any transactions forming part of a tax arrangement or have obtained a tax benefit as a result. These may include individuals, legal entities, or organizational units without legal personality.
Reporting deadline
For tax arrangements related to CIT, the deadline for submitting MDR-3 coincides with the due date for filing the CIT return for 2024, which falls on March 31, 2025 (assuming the tax year aligns with the calendar year).
Scope of reporting
The MDR-3 reporting obligation by the specified deadline applies to both cross-border and domestic tax arrangements.
It is important to note that the requirement to report domestic tax arrangements may arise simply from exceeding specific value thresholds for a taxpayer’s transactions. For example, this may occur when a non-resident’s income (revenue) or a dividend payment exceeds PLN 25 million. In such cases, reporting is required if the entity meets the criteria of a qualified beneficiary.
Recommended actions
It is advisable to review transactions and activities carried out over the past year to ensure that all MDR-related obligations have been duly fulfilled and to identify any outstanding reporting requirements due by the end of March.
Failure to comply with MDR obligations may result in penalties, including significant financial sanctions.
How can we assist?
We are pleased to offer our expertise in analyzing your MDR reporting obligations, leveraging both our experience and market knowledge.
If needed, we can guide you through the entire reporting process, outlining the applicable requirements, collecting the necessary data, and preparing and submitting the required documentation. Additionally, we can assist in optimizing internal processes related to tax arrangement reporting, developing necessary procedures, and more.
We provide accounting and tax services for real estate companies.
