Judgments: retroactive deprecation and non-taxation on liability’s expiration

Today we present you two very important rulings of the Supreme Administrative Court from the past week. Retrospective reduction of depreciation rates The taxpayer (company) had a number of fixed assets. Due to the incurred tax losses, the company considered the possibility of lowering the depreciation rates also for the previous years, taking into account

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Judgment: undocumented costs are tax non-deductible

The taxpayer purchased a number of intangible services (advertising / market research / advisory services), which he classified as tax-deductible costs in CIT. Tax authorities ruled on their exclusion from tax-deductible costs due to the lack of documentation confirming their performance. The decision was appealed against to the District Administrative Court in Gliwice. The taxpayer

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General interpretation – participatory exemption, general partnerships and limited partnerships

The Minister of Finance issued a general interpretation (sign. DD5.8203.2.2021) regarding the application of the so-called “participatory exemption” of income (profits) obtained from participation in the profits of general partnerships and limited partnerships which are CIT taxpayers (pol. spółka komandytowa and Spółka jawna). The Minister stated that this exemption may apply to income (profits) generated

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The “Polish Deal” significantly modified and passed to the Sejm

The Council of Ministers adopted a substantially modified draft amendment to tax regulations under the “Polish Deal” programme. The document has now been submitted to the Sejm. Below we present a synthetic overview of the most important changes in relation to the original proposals. 1. Health insurance contribution The adopted project specifies that the basis

Significant tax reform

The Ministry of Finance has published a comprehensive draft amendment to tax regulations as part of the “Polish Deal” program. A very extensive document (225 pages) includes many changes in various taxes (PIT, CIT, VAT). Below we present a synthetic overview of the most important of them. 1. Principles of tax progression (PIT) As part

No tax on redemption (Financial Shield)

The Minister of Finance signed a decree on redemption of tax on income (revenues) due to redemption of financial subsidies granted from the Financial Shield of the Polish Development Fund. The non-collection of tax will apply to the income (revenue) obtained by the beneficiaries of the support from June 1, 2021 to December 31, 2022.

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Telematics services and withholding tax

Telematics services are becoming more and more popular, especially for companies with a large fleet of vehicles. The vehicles are fitted with devices that enable their tracking (using GPS), downloading data from on-board computers, etc. Such effects are achieved thanks to special software. In practice, as in the case of many other services, suppliers of

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Capital repatriation program and changes in transfer pricing

The Ministry of Finance presented another set of tax proposals under the “Polish Deal” program. Their guiding idea is the return (repatriation) of capital to Poland. Additionally, it is proposed to simplify the provisions on transfer pricing. Transfer pricing simplifications Following the decisions of the Transfer Pricing Forum, the Ministry proposes the following solutions: elimination

“The Polish Deal”: Tax relief for increasing sales, Polish Holding Company, Investment agreement

The Ministry of Finance has published further proposals for tax changes in the so-called Of the “Polish Deal”. They include, in particular, the following. Relief for increasing sales The relief of the relief is another novelty in the Polish tax system. The taxpayer could deduct from the income the costs incurred in order to increase

Another tax proposals as part of the “Polish Deal”

The Ministry of Finance presented another package of proposals for taxpayers under the “Polish Deal” program. They focus on facilitating easier settlements and new tax reliefs. The regulations are to enter into force on 1 January 2022. The “Estonian CIT” The Ministry proposes to simplify the regime and to make it more accessible, especially through:

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