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Foreign controlled entities (CFCs) – tax on pass-through income
Pass-through income is defined as a specific type of tax-deductible expenses incurred by a taxpayer to a non-resident related party during the tax year. Taxes on pass-through income at a rate of 19% on the taxable base must be paid by taxpayers provided several conditions are met. I. The taxpayer...
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New deadlines in transfer pricing
In view of the approaching deadlines for the fulfilment of documentation and information obligations in transfer pricing, we would like to remind you that with regard to the fulfilment of transfer pricing obligations for 2022, there is a fundamental change in the deadlines in relation to previous years (previously extended...
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State of epidemic emergency cancellation and MDR deadlines
We would like to inform you that as of 1st of July 2023, the state of epidemic emergency related to SARS-CoV-2 virus infections on the territory of the Republic of Poland will be lifted. We point out that the revocation of the epidemic emergency has important implications on the ground...
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Withholding Tax (WHT) 2023
Interest, royalties, and others Interest and royalties paid to a non-resident and fees for certain intangible assets and legal services (e.g. consulting, accounting, legal and technical services, advertising, data processing, market research, recruitment, management, inspection services and guarantees, etc.) are subject to 20% withholding tax, unless the rate is not...
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Extension of deadlines for filing CIT returns for 2022
We would like to inform you that on 21 March 2023, a regulation was published in the Journal of Laws 2023, item 530 extending the deadlines for filing corporate income tax returns for the tax year that ended between 1 December 2022 and 28 February 2023. The extended deadline also...
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Estonian CIT – current legal status 2023
Estonian CIT is referred in the law as a lump sum on income of capital companies. It is a modern way of taxation that promotes investments and minimizes formalities when settling taxes for capital companies and partnerships. This solution is addressed to: micro, small and medium-sized capital companies and partnerships...
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Extended deadline for filing ORD-U information
Please be advised that, based on the Ordinance of the Minister of Finance dated 16 February 2023 amending the Ordinance of the Minister of Finance of 24 December 2002 on tax information, the deadline for filing the Information on Agreements concluded with non-residents (ORD-U) will be extended. According to the...
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Deadline for submission of information by real estate companies and their partners
We would like to remind you of the upcoming deadline for the obligation to submit certain information regarding real estate companies for 2022 to the competent tax authorities (for most taxpayers, the deadline is 31 March 2023). The entities obliged to submit the information are real estate companies and PIT/CIT...
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Obligation for a company to file a CbC-P notification or CbC-R report
Country-by-Country report (CBC-R) is a reporting mechanism set out in the Act of 9 March 2017 on the exchange of tax information with other countries. Entities belonging to large multinational groups are obliged to report tax information related to that capital group to the National Tax Administration. In order to...
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Amendments to the Corporate Income Tax Act and certain other acts (Polish Deal 3.0)
Published on 25 October 2022, the Act of 7 October 2022 introduces new regulations for taxpayers. For the most part, the changes under the Act apply to CIT and come into force on 1 January 2023, with some exceptions (Polish Deal 3.0). A particularly significant change is the exemption from...
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