There are significant chances to eliminate the provisions on the documentation obligation in the field of “indirect tax heaven” transactions. Let us remind you that it is about the obligation to prepare transfer pricing documentation in transactions with unrelated entities, if their beneficial owner is a “tax heaven” entity. This regulation has been repeatedly criticized

The Ministry of Finance has published a draft regulation which is to extend the validity of statements (WH-OSC) for the purposes of withholding tax collection. As a reminder, if payments for dividends, interest and royalties to related entities exceed the threshold of PLN 2 million in the tax year, tax must be charged at the

Disputes between entrepreneurs are common in business activities. Some of them end at the pre-trial stage, e.g. by concluding a settlement. What are the consequences of concluding such a settlement in terms of income taxes? Let us consider it on the example of a settlement in which the entrepreneur infringing someone else’s copyright undertakes to

The draft amendment to the CIT Act has been published on the website of the Government Legislation Center – specifying the provisions of the previously commented assumptions: Below we present to you the important issues that have been clarified in this project (in relation to the assumptions). “Tax heaven”-related transactions The draft provides for very

We would like to inform you that the proposal to the act amending the provisions of the Polish CIT Act has been published on the website of the Government Legislation Center. The project is to be a response to the demands of the business and advisors in terms of changes introduced by the “Polish Deal”.

The President signed an act amending the “Polish Deal”. We are waiting for the publication of the act in the “Journal of Laws”. The rules, in principle, enter into force in July. The most important changes include: reduction of the PIT rate from 17% to 12% (under the first tax threshold) for taxpayers settling on

In business practice, there are situations of bankruptcy of contractors. The creditors are then left with unpaid receivables. Some of them wonder whether to report them at all in the pending proceedings. Meanwhile, this circumstance is of great practical importance. At the outset, it is worth recalling that recognition of a bad debt, previously booked

The European Commission presented a proposal of solutions concerning the possibility of deducting the value of the capital increase from the tax base. It is a solution that is to build a “counterbalance” to the currently abused – according to the European Commission – debt financing. The genesis of the proposed solutions goes back to

The company leased equipment (locomotives) on the basis of leasing contracts, which for tax purposes were operating leasing (balance sheet financial leasing). The company asked whether the locomotive lease payments constitute debt financing costs within the meaning of the thin capitalization provisions (Article 15c of the Polish CIT Act)? In the opinion of the Company,