The Polish Holding Company (PHC) is a solution that has been effective in the CIT Act since 1 January, 2022 and is intended to encourage investors to invest through Polish holding companies in other entities. In principle, the PHC allows for an exemption from taxation of dividend income paid by a Polish/foreign subsidiary to a…
On 8 November 2022[1], the Court of Justice of the European Union (‘the CJEU’) annulled the decision of the European Commission and the judgment of the EU Court, which recognized the individual ruling issued by the authorities in Luxembourg as providing a ‘selective advantage’ to Fiat Chrysler Finance Europe, which – according to the Commission…
Autumn has come and it has been followed by another changes in tax regulations, including the flat-rate income tax, or so-called withholding tax. Background to the changes The current version of the withholding tax regulations came into force on 1 January 2022. However, the fact that the legislator plans to amend the withholding tax rules…
The end of the year is approaching. Most companies are making the final settlements for the entire 2022. This is the last moment to thoroughly analyze any necessary adjustments to settlements, prices or terms of contracts. Meanwhile, adjustments constantly raise interpretation doubts – in terms of their definition as well as specific conditions for correct…
Transactions involving intangible assets are among related-party transactions causing the greatest difficulties for taxpayers when meeting their transfer pricing obligations. Taxpayers often find it challenging to prepare the valuation of intangible assets itself. They also need to remember that in the case of transfer pricing it is also necessary to adopt market assumptions for transactions…
Some taxpayers currently compiling Local Files and TP-R forms for 2021 will not complete their struggle with transfer pricing on 31 December 31 (if their tax year matches the calendar year). They will face additional obligations related to Master File for 2021. What is Master File? The Master File is (shortly) an integral part of…
The most important change concerning the minimum tax is the exemption of taxpayers from this tax in 2022 and 2023. For taxpayers whose fiscal year is different from the calendar year and starts before 1 January 2024 and ends after 31 December 2023, the exemption will apply until the end of that fiscal year. The…
The reform of Estonian CIT (sometimes called as “lump sum taxation”) under the Polish Deal, which began in 2022, allowed for a significant expansion of access to this form of taxation, e.g. by expanding the catalogue of entities eligible to apply Estonian CIT, reducing the flat rate on income, and abolishing the revenue limit. Thanks…
There is less than a month left to meet the transfer pricing reporting deadlines. One of the obligations is to file to the Polish tax office a statement on transfer pricing documentation and on the arm’s length nature of the transaction. The statement shall be signed by members of the company’s management board. For most…
Taxpayers actively promoting their own products may, starting from 2022, make more deductions from their tax base. Tax credit for enhanced product sales is a kind of closing bracket for other deductions introduced with regard to taxpayers’ manufacture of their products. This time, the legislator touches upon the final element of selling one’s own products,…