The article's subject is obligation to submit CBC-P notification, which is one of the stages of the automatic exchange information between tax authorities. This obligation is related to Country-by-Country reporting proposed under the Action Plan on Base Erosion and Profit Shifting. Entities operating in the structures of international groups are required to submit the CBC-P notification every year, by the end of the third month from the end of the group's reporting financial year. The article analyzes the most important problems related to the submission of the CBC-P notification, including the origins of this obligation, related to the fight against international tax avoidance, the subjective scope of the obligation to submit CBC-P, as well as penalties related to failure to submit this notification and its proportionality and the possibility of avoiding the imposition of such penalty.