We would like to draw your attention to a new and controversial line of interpretation regarding the conditions for applying the withholding tax exemption on dividends paid to parent companies, which can be observed in a series of recent rulings of the Provincial Administrative Court in Lublin (an example of...
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On November 14, 2023, the Ministry of Finance has published a draft regulation on its website, that expands the catalogue of types of receivables that can be paid via tax micro-accounting. According to the information provided by the Ministry of Finance, the draft was prepared to update the list of...
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From 1 January 2024, minimum rules for corporate income tax will come into force in accordance with Article 24ca of the CIT Act. This tax is intended to tighten the tax system and minimise the tendency to shift income from Polish companies to jurisdictions with a favourable tax regime. The...
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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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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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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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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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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 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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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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