Due diligence – transfer pricing documentation

The Ministry of Finance has published a draft “Explanations” on transfer pricing documentation, regarding the presumption of due diligence. Let us remind you that, in accordance with the amended income tax regulations, taxpayers are required to prepare transfer pricing documentation also in transactions with unrelated parties, if the beneficial owner of such entity has its

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Extension of terms – TPR, CIT

On the 25th of February, the Sejm adopted an amendment according to which the deadlines for submitting information on TPR transfer pricing and a declaration on the preparation of local transfer pricing documentation were extended: until September 30, 2021 for entities whose reporting and documentation obligations expire in the period from February 1, 2021 to

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4 new general rulings

The Ministry of Finance published, yesterday and today, 4 new general ruling concerning: changes in the scope of the leasing contract and sale of the subject during its term, settlements when using fuel cards, sale of own receivables in factoring, and taxation of vocational training. Changing the lease agreement, selling leased items The Minister of

Verifying contractors in 2021, must one be even more diligent?

As part of counteracting the erosion of tax receivables, the legislator has for some time been imposing on taxpayers new obligations to verify contractors. Their common denominator is to make the taxpayer (or remitter) “jointly responsible” for the correct tax settlements under the transaction. The taxpayer (or the remitter) should, in particular, verify the status

2021 loan in tax settlements

How will loans concluded in 2021 differ from those in previous years in terms of taxation? Significant changes in tax law regulations that come into force at the beginning of each new year no longer surprise anyone. Practice shows that the changes concern many aspects, and their main principle is a “spot” intervention in order

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Amendments to the CIT and PIT Acts published in the Journal of Laws

Today, the provisions amending the Polish CIT and PIT Act were published in the Journal of Laws. Taxation of limited partnerships (spółka komandytowa) and other changes The Act of November 28, 2020 introduces the following changes : limited partnerships and general partnerships having their seat or management board in the territory of the Republic of

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WHT and the gross-up clause

Payment of remuneration to foreign entities may result in the obligation to collect the withhold tax (WHT). This applies to the payment of dividends, interest, royalties or remuneration for specific services. Theoretically, the tax is borne by the recipient. Therefore, it should receive its value after the WHT deduction. Nevertheless, some foreign contractors demand to

Changes in income taxes passed by the Sejm

In addition to the “Estonian CIT”, changes in the area of ​​income taxes include other very important issues, such as: covering limited partnerships (pol. spółka komandytowa) with CIT – starting from May 2021, although it will be possible to choose this option from the beginning of the year; liquidation of the so-called “abolition relief”; limiting

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“Estonian CIT” passed by the Sejm

On October 28, the Sejm passed an amendment to the provisions of the Corporate Income Tax Act, introducing tax solutions, commonly known as “the Estonian CIT”. Just to remind, this is a special tax regime that provides for taxation of income only at the time of distribution or allocation of funds for private purposes of

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