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  • Article

    New Thin Capitalisation Rules In Poland

    Since 2018, new thin capitalisation rules have been present in Poland, as an implementation of the Anti-Tax Avoidance Directive (ATAD) into the Polish tax system.
    PolandTax
    Taylor Wessing
    Taylor Wessing
  • Article

    New Transfer Pricing Requirements In Poland

    The amendment of Poland's CIT act includes substantial changes to required transfer pricing documentation for taxpayers.
    PolandTax
    TMF Group BV
    TMF Group BV
  • Article

    Tax Review - April 2016

    We are proud to present the next edition of our Tax Review which contains a selection of rulings and interpretations that were issued or published in March 2016.
PolandTax
Dentons
Dentons
  • Article

    Poland Has Lost The Case Before The European Court Of Justice On Excise Duty On Energy

    As a result of the trial that was held before the European Court of Justice upon a motion of the Commission of the European Communities, the following judgment has been passed.
    PolandTax
    DLA Piper
    DLA Piper
  • Article

    Principles Of Revenue And Tax Deductible Costs Adjustment Made In Connection With Issued/Received Correction Invoices

    Provisions of the Personal Income Tax Act and Corporate Income Tax Act do not specify when the taxpayer should adjust revenue or costs in connection with received or issued correction invoices.
    PolandTax
    Dentons
    Dentons
  • Article

    Alert On Key Recent Changes To Polish Tax Legislation

    With reference to our meeting in Amsterdam I hasten to update you with respect to the most recent legislative changes and practical aspects of Polish tax legislation.
    PolandTax
    Soltysinski Kawecki & Szlezak
    Soltysinski Kawecki & Szlezak
  • Article

    Planned Significant Changes In The CFC Regulations In Poland

    On July 17, 2017 the Polish Government filed a draft law amending, among others, the 1991 Personal Income Tax Law and the 1992 Corporate Income Tax Law.
    PolandTax
    Gessel - Attorneys at Law
    Gessel - Attorneys at Law
  • Article

    Retail Sector Tax Suspended In Poland

    Poland's Minister of Finance announced that the application of a retail sector tax will be suspended following the EC's decision on opening an in-depth investigation and issuance of an interim injunction.
    PolandTax
    Wolf Theiss
    Wolf Theiss
  • Article

    Managing A Foreign Fund In A Manner That Differs From The Polish Model Does Not Preclude The Right To A CIT Exemption In Poland For The Income Of A Foreign Investment Fund

    A private investment fund headquartered in Cyprus (the "Fund") applied for a tax ruling regarding the right to a CIT exemption.
    PolandTax
    Dentons
    Dentons
  • Article

    CIT Consequences Of A Transfer Of Assets Of A Liquidated Limited Liability Company To Its Sole Shareholder

    Article 14a of the CIT Act is a source of controversy and we will definitely be seeing more judgments elaborating on the rules of its interpretation.
    PolandTax
    Dentons
    Dentons
  • Article

    Definition Of Loan On The Grounds Of CFC Regulations

    On June 25, 2015 the Director of the Tax Chamber in Katowice issued a tax ruling (ref. no. IPTPB3/4510-103/15-4/ PM) holding that the concept of 'loan' on the grounds of CFC regulation must be construed broadly...
    PolandTax
    Dentons
    Dentons
  • Article

    Rent Agreements – A Hidden Tax Trap For Family Foundations?

    Polish tax authorities are challenging the tax-exempt status of short-term rental activities conducted by family foundations, despite the Family Foundation Act's provisions allowing such operations. While administrative courts have consistently ruled in favor of taxpayers, the absence of a Supreme Administrative Court decision leaves the matter unresolved.
    PolandTax
    GGI | Global Alliance
    GGI | Global Alliance
  • Article

    Differences Between International Financial Reporting Standards (IFRS) And Polish Accounting Standards

    International Financial Reporting Standards (IFRS) and Polish accounting standards present fundamentally different approaches to recording business transactions and assessing a company's financial position. These differences significantly impact asset valuation, liability recognition, revenue timing, and ultimately how investors, banks, and business partners perceive a company's financial health and creditworthiness.
    PolandAccounting and Audit
    GGI | Global Alliance
    GGI | Global Alliance
  • Article

    The Annulment Of The CIT Exemption For Closed-End Investment Funds – Next Stage Of The Legislative Procedure

    The first reading of the Bill on the amendment of the Personal Income Tax Act and the Corporate Income Tax Act, which was submitted to the Sejm on 31 October 2016, took place in the Sejm on 4 November 2016
    PolandTax
    Dentons
    Dentons
  • Article

    Amendments Of CIT And PIT Acts In Poland

    On 5 September 2016, the lower chamber of the Polish parliament (Sejm) accepted changes made by the Senate to the Act amending PIT and CIT.
    PolandTax
    Dentons
    Dentons
  • Article

    New Tax Incentives For The R&D Sector

    On October 16, 2015, the President of Poland signed Amendments to Certain Acts Related to Supporting Innovation Act of September 25, 2015.
    PolandTax
    Dentons
    Dentons
  • Article

    Loan Currency Conversion Does Not Generate Any Foreign Exchange Differences

    In its request for a tax ruling, the company sought confirmation that at the time of selling the foreign currency to the bank certain foreign exchange tax differences were generated on the company's part.
    PolandTax
    Dentons
    Dentons
  • Article

    No Possibility To Change The Qualification Of Revenue Upon Discharge Of An Obligation

    In an award of 29 July 2015, the Province Administrative Court in Warsaw ("WSA") held that the company does not have the possibility to make an adjustment of revenue that was previously ascertained as a result of an inspection.
    PolandTax
    Dentons
    Dentons
  • Article

    Regulation Changes In Poland

    The Polish government has made concerted efforts in recent years to ease bureaucracy and improve the business environment for companies and those looking to invest.
    PolandTax
    TMF Group BV
    TMF Group BV
  • Article

    Remuneration In Consideration Of Loans Extended And Calculated As A Percentage Of Profits Achieved Is Not Classifiable As Tax Deductible Cost For The Remuneration Paying Company

    The Company (the Borrower) entered into a loan agreement with a foreign entity (the Lender) for the sole purpose of financing a development project.
    PolandTax
    Dentons
    Dentons
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