End of documenting indirect “tax heaven” transactions?

There are significant chances to eliminate the provisions on the documentation obligation in the field of “indirect tax heaven” transactions. Let us remind you that it is about the obligation to prepare transfer pricing documentation in transactions with unrelated entities, if their beneficial owner is a “tax heaven” entity. This regulation has been repeatedly criticized

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Tax strategy in practice

2022 will be the second year in which some taxpayers will be required to publish information about the tax strategy implemented in this period. Who does this obligation apply to? CIT taxpayers whose revenue in the preceding year exceeded the PLN equivalent of EUR 50 million and tax capital groups. In practice, some taxpayers already

Legislation and practice – July in taxes

We present below a short summary of the most important changes in tax law and tax practice in July: the Decree amending the decree on goods and services for which the tax rate on goods and services is lowered, and the conditions for the application of reduced rates was published in the “Journal of Laws”

Extending the validity of WHT statements

The Ministry of Finance has published a draft regulation which is to extend the validity of statements (WH-OSC) for the purposes of withholding tax collection. As a reminder, if payments for dividends, interest and royalties to related entities exceed the threshold of PLN 2 million in the tax year, tax must be charged at the

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Settlement – income and costs

Disputes between entrepreneurs are common in business activities. Some of them end at the pre-trial stage, e.g. by concluding a settlement. What are the consequences of concluding such a settlement in terms of income taxes? Let us consider it on the example of a settlement in which the entrepreneur infringing someone else’s copyright undertakes to

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Tax interpretations and MDR

As a part of the counteractions against the erosion of taxation and the shift of profits, OECD developed the so-called “BEPS” package, one of the elements of was a system for informing tax authorities about tax planning mechanisms – Mandatory Disclosures Rules. This mechanism was reflected in the Council Directive (EU) 2018/8221 of May 25,

Selected details of CIT amendments

The draft amendment to the CIT Act has been published on the website of the Government Legislation Center – specifying the provisions of the previously commented assumptions: Below we present to you the important issues that have been clarified in this project (in relation to the assumptions). “Tax heaven”-related transactions The draft provides for very

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Proposed amendments to CIT Act

We would like to inform you that the proposal to the act amending the provisions of the Polish CIT Act has been published on the website of the Government Legislation Center. The project is to be a response to the demands of the business and advisors in terms of changes introduced by the “Polish Deal”.

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Entry into force of changes in the “Polish Deal”

The President signed an act amending the “Polish Deal”. We are waiting for the publication of the act in the “Journal of Laws”. The rules, in principle, enter into force in July. The most important changes include: reduction of the PIT rate from 17% to 12% (under the first tax threshold) for taxpayers settling on

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Filing insolvency claim – impact on tax costs

In business practice, there are situations of bankruptcy of contractors. The creditors are then left with unpaid receivables. Some of them wonder whether to report them at all in the pending proceedings. Meanwhile, this circumstance is of great practical importance. At the outset, it is worth recalling that recognition of a bad debt, previously booked

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