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
- Published in CIT
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
- Published in CIT
DEBRA – tax deduction on capital
The European Commission presented a proposal of solutions concerning the possibility of deducting the value of the capital increase from the tax base. It is a solution that is to build a “counterbalance” to the currently abused – according to the European Commission – debt financing. The genesis of the proposed solutions goes back to
- Published in CIT
Judgment: Operating lease costs are not covered by thin capitalization
The company leased equipment (locomotives) on the basis of leasing contracts, which for tax purposes were operating leasing (balance sheet financial leasing). The company asked whether the locomotive lease payments constitute debt financing costs within the meaning of the thin capitalization provisions (Article 15c of the Polish CIT Act)? In the opinion of the Company,
- Published in CIT
Proposed changes to the “Polish Deal”
Today, Prime Minister Mateusz Morawiecki and Deputy Minister of Finance Piotr Soboń presented proposed changes to the “Polish Deal”, which are to meet “the opinions of taxpayers and experts”. The regulations are to come into force in July this year (although there is no bill yet). Below, the proposals for new solutions presented at the
Judgments: retroactive deprecation and non-taxation on liability’s expiration
Today we present you two very important rulings of the Supreme Administrative Court from the past week. Retrospective reduction of depreciation rates The taxpayer (company) had a number of fixed assets. Due to the incurred tax losses, the company considered the possibility of lowering the depreciation rates also for the previous years, taking into account
- Published in CIT
Judgment: undocumented costs are tax non-deductible
The taxpayer purchased a number of intangible services (advertising / market research / advisory services), which he classified as tax-deductible costs in CIT. Tax authorities ruled on their exclusion from tax-deductible costs due to the lack of documentation confirming their performance. The decision was appealed against to the District Administrative Court in Gliwice. The taxpayer
- Published in CIT
General interpretation – participatory exemption, general partnerships and limited partnerships
The Minister of Finance issued a general interpretation (sign. DD5.8203.2.2021) regarding the application of the so-called “participatory exemption” of income (profits) obtained from participation in the profits of general partnerships and limited partnerships which are CIT taxpayers (pol. spółka komandytowa and Spółka jawna). The Minister stated that this exemption may apply to income (profits) generated
- Published in CIT
The “Polish Deal” significantly modified and passed to the Sejm
The Council of Ministers adopted a substantially modified draft amendment to tax regulations under the “Polish Deal” programme. The document has now been submitted to the Sejm. Below we present a synthetic overview of the most important changes in relation to the original proposals. 1. Health insurance contribution The adopted project specifies that the basis
Significant tax reform
The Ministry of Finance has published a comprehensive draft amendment to tax regulations as part of the “Polish Deal” program. A very extensive document (225 pages) includes many changes in various taxes (PIT, CIT, VAT). Below we present a synthetic overview of the most important of them. 1. Principles of tax progression (PIT) As part