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Poland Publishes Regulation Providing Deferral for DAC6 Reporting

Poland has published the Ministry of Finance Regulation of 30 June 2020 in the Official Gazette, which provides for the deferral of reporting on cross-border arrangements (DAC6) provided by Council Directive (EU) 2020/876. Because Poland already implemented reporting requirements from 2019, however, the deferrals are implemented a little differently than what other EU Member States are providing. The deferrals are as follows:

  • The recently revised retroactive reporting of arrangements between 26 June 2018 and 30 June 2020 is deferred to:
    • 31 December 2020 for promoters (intermediaries);
    • 31 January 2021 for beneficiaries; and
    • 28 February 2021 for service providers;
  • The general 30-day reporting period for reportable arrangements up to 31 December 2020 begins from 1 January 2021.

The Regulation also provides deferrals in relation to financial account reporting in relation to CRS and FATCA.

Note, the deferral of the standard 30-day reporting period to begin 1 January 2021 does not apply with respect to deadlines that elapsed prior to the Regulation's entry into force (30 June 2020).

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