Tax on shifted profits for 2023
It should be reminded that with the upcoming annual settlement, the so-called tax on shifted profits must be settled. What are “shifted profits”? It should be recalled that shifted profits are, in principle, defined costs incurred directly or indirectly for the benefit of a foreign related entity due to: – if the conditions set out
- Published in CIT
Legislation and Practice – February in taxes and business law
We present below a short summary of the most important changes in tax/business law and practice in February. Legislation Tax Practice Income taxes and transfer pricing VAT International Taxes Other
- Published in CIT
Limited partnership and participation exemption
The subject of taxation of a limited partnership and its partners is the subject of many publications. This applies primarily to payments from the company to general partners and limited partners. The latter topic has even become the subject of the general interpretation of the Minister of Finance of 17 December 2021, file reference number
- Published in CIT
B2B and B2C cash transaction limits in 2024
One of the elements of the Act amending the Personal Income Tax Act, the Corporate Income Tax Act and certain other acts, known as the “Polish Deal”, was the modification of the provisions on cash payment limits. At that time, the B2B payment limit was modified (up to PLN 8,000.00) and the B2C payment limit
- Published in CIT
Foreign artists’ fees and withholding tax (WHT)
King Charles awarded the singers of the Korean band Blackpink with the Orders of the British Empire, and soon we can expect their concerts in other parts of Europe, including Poland. Taylor Swift, after being named Time magazine’s Person of the Year 2023, is embarking on a major tour of Europe starting in the new
- Published in CIT
MPLS and Polish withholding tax
MPLS is a routing technique in telecommunications networks that directs data from one node to the next based on labels rather than network addresses (source: Wikipedia). It is more and more often an element of settlements with software providers to Polish taxpayers. If the service provider is a foreign entity, then the issue of withholding
- Published in CIT
Sponsorship relief on sports activities – what to watch out for?
“The Polish Deal” introduced an additional relief in income taxes (PIT and CIT), called “sponsorship” or “CSR” relief (Article 18ee of the Polish CIT Act and Article 26ha of the Polish CIT Act). It consists in the possibility of an additional deduction from the tax base of, among other things, 50% of tax-deductible expenses incurred
- Published in CIT
Intermediary services (agent) are not subject to WHT in Poland
The applicant is a Polish company that plans to enter into an agency agreement with a company in India (agent). The agent will act as an intermediary for the sale of the applicant’s products on the Indian market. His tasks will include representing the company, attending meetings, making offers on behalf of the company, answering
- Published in CIT
Notional interest deduction also with the payment of profit from previous years
Polish CIT regulations have provided tax preferences for entities accumulating profits for several years. This instrument is the recognition of the amount of “hypothetical” interest on own financing (notional interest deduction) as tax deductible costs. According to Article 15cb sec. 1 point 2 of the Polish CIT Act the tax deductible cost is also the
- Published in CIT
ORD-U and TPR
In principle, entities that prepare and submit TPR information do not have to submit ORD-U declarations. There is an exception to this rule – it applies to taxpayers who make transactions with “tax heaven” entities (Article 11k sec. 2a of the Polish CIT Act). This results from the regulation of Article 82 § 1c of
- Published in CIT