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Transfer pricing: The next amendment
A revised bill to amend tax regulations as part of the “Polish Deal” has been submitted to the parliament. How do the proposals involving transfer pricing look now?
Transfer pricing: The next amendment
Social insurance notification by a foreign undertaking of contracts for specific work
Whether a foreign undertaking should notify the Social Insurance Institution of contracts for specific work it has concluded is determined primarily by whether the undertaking has the status of a remitter of contributions within the meaning of Polish law.
Social insurance notification by a foreign undertaking of contracts for specific work
“Slim VAT 2”: Another reform of VAT settlements
On 19 August 2021, the President of Poland signed an act introducing a number of simplifications to VAT settlements. The changes are intended to improve taxpayers’ liquidity in connection to VAT settlements, deformalise certain procedures, and implement decisions of the Court of Justice of the European Union in cases lost by Poland.
“Slim VAT 2”: Another reform of VAT settlements
Proposed changes in transfer pricing regulations
Transfer pricing regulations have been included in the package of proposed changes to tax law implementing the political programme known as the Polish Deal. Some of these changes respond to market expectations and deserve applause. Others will complicate taxpayers’ lives. Here we examine the proposed solutions.
Proposed changes in transfer pricing regulations
The Polish Deal: Consolidation relief and changes in tax treatment of debt financing costs
The proposed tax changes under the Polish Deal programme enshrine in law a method of calculating the debt financing cost limit which is disadvantageous for taxpayers. They offer a carrot to buyers of shares in the form of a deduction from the tax base of qualified expenditures on the acquisition of shares as part of consolidation relief, but also a stick in the form of a complete ban on treating interest on debt financing obtained from related parties for the acquisition of shares as a tax-deductible cost.
The Polish Deal: Consolidation relief and changes in tax treatment of debt financing costs
Preferences for PIT payers investing in alternative investment companies and new conditions for the tax exemption for AICs from 2022
The bill published on 26 July 2021 to amend the Personal Income Tax Act, the Corporate Income Tax Act and certain other acts, known as the Polish Deal, provides payers of personal income tax with a new preference to encourage investments in ventures carrying high economic risk. The proposed relief is intended to apply to certain investments by PIT payers in an alternative investment companies or their subsidiaries.
Preferences for PIT payers investing in alternative investment companies and new conditions for the tax exemption for AICs from 2022
Proposed changes would increase tax burdens on top earners
One of the flagship elements of the political programme called the “Polish Deal” is changes in personal income tax and social insurance contributions. This will lead to a drastic increase in the burden on top earners, especially business operators.
Proposed changes would increase tax burdens on top earners
Benefits for people returning from abroad, tax holidaymakers, and tax optimisers coming in from the cold
A comprehensive overhaul of Polish tax law is expected. The proposed changes would implement the Law & Justice government’s programme known as the “Polish Deal.” Some of these changes are intended to make the tax system more attractive to new taxpayers. Others are designed to encourage taxpayers who have used optimisation schemes in the past to put their tax affairs in order.
Benefits for people returning from abroad, tax holidaymakers, and tax optimisers coming in from the cold
New tax regime for holding companies: Who will benefit from it?
The new regime is intended to incentivise holding companies to locate in Poland and create a competitive tax environment encouraging Polish businesses to return from foreign jurisdictions. These themes resound from the explanatory memorandum to the bill introducing the “Polish Deal.” But do the proposed provisions actually reflect these ideals? Will the new regime be attractive to any group of taxpayers?
New tax regime for holding companies: Who will benefit from it?
New tax options for capital groups: VAT groups in Poland
The bill to implement the “Polish Deal” programme would introduce the separate institution of a VAT group, previously unknown in the Polish tax system, enabling consolidation of the tax result within a capital group.
New tax options for capital groups: VAT groups in Poland
Depreciation of real estate belonging to real estate companies
The bill to amend the Personal Income Tax Act, the Corporate Income Tax Act and other acts published on 26 July 2021, known as the “Polish Deal,” includes new rules for tax depreciation of real estate held by real estate companies. The proposed changes could significantly limit the value of tax costs from depreciation.
Depreciation of real estate belonging to real estate companies
“590 interpretation”: Investment agreement with the Minister of Finance for new investments
The Ministry of Finance has proposed regulations allowing for conclusion of an investment agreement (also called a “590 interpretation”) between an investor and a tax authority—an agreement on the tax consequences of a planned or commenced new investment in Poland. It is supposed to constitute a binding opinion for the tax authorities on all tax consequences of the planned investment. Thus the investment agreement should be an effective tool for removing investment barriers in Poland and thus encouraging more investments, including foreign investments. In particular, it will be addressed to foreign entities planning to commence business in Poland, but current taxpayers in Poland will also be able to take advantage of it.
“590 interpretation”: Investment agreement with the Minister of Finance for new investments