EMIR 3 in Polish jurisdiction. OTC derivative instruments
EMIR 3 in terms of the core EMIR regulation – the most important bullet points based on the experience of KIEŁTYKA GŁADKOWSKI KG LEGAL in advising global clients in the Polish jurisdiction in the field of derivative instruments traded over the counter.
Exit fee and tax consequences – recent interpretation of Polish National Revenue Centre. How it is used within the framework of intra-group restructuring of activities.
Exit fee is a fee for transferring assets, functions or risks between related entities. It can be understood as remuneration for the transfer of important functions, assets or risks. It is paid during business restructuring, either once or periodically. On 30 January 2025 there has been issued important interpretation of the Director of the Polish …
Application of the look-through approach concept in Poland – new tax rulings and interpretations
Practical comments on beneficial owner, treaty shopping, beneficial owner clauses for dividends, beneficial owner clauses for interest, substitute companies and abusive clauses, the status of a beneficial owner in various types of intermediary centres between service orderers and service providers, withholding tax on interest paid within the cash pooling structure.