On January 1, 2024, the minimum corporate income tax provisions of Article 24ca of the CIT Law will begin to apply. Therefore, we are starting a series of publications in which we will introduce the assumptions of minimum income tax and indicate how to determine whether it will apply to a particular organization and, ultimately,…
Jacek Wojtach of MDDP Poland explains the Polish withholding tax rules and refund procedures, and the issues that could be addressed as the European Commission declares its intention to make legislative changes. On June 19 2023, the European Commission issued a statement signalling legislative work on simplifying and synchronising members states’ laws on pay and…
Justyna Bauta-Szostak and Bartosz Głowacki of MDDP report on the introduction of family foundations in Poland, and how they will be taxed. On January 26 2023, the lower house of the Polish parliament, the Sejm, passed the Family Foundation Act, which will enter into force in May 2023. The purpose of a family foundation, which…
Bartosz Doroszuk of MDDP offers insights on Poland’s new tax legislation on shifted profits, as the implementation deadline looms nearer. The new tax on shifted profits has been implemented via the Polish CIT Act from January 1 2022. Since this tax is settled on annual basis, the upcoming deadline for the annual CIT return would…
Bartosz Głowacki of MDDP analyses the new rules surrounding the Polish Investment Zone, with significant tax windfalls to be found by intrepid investors. From January 1 2023 there are new rules on regional investment state aid in the Polish Investment Zone. The Polish Investment Zone provides corporate income tax exemption in return for investment in…
Magdalena Zamoyska and Monika Grobelska of MDDP explain a series of amendments for 2023 that are expected to improve the accessibility and functioning of the Polish holding company model. A capital gains tax participation exemption for holding companies was introduced into Polish tax law under the so-called Polish holding company model from January 1 2022.…
The Polish Holding Company (PHC) is a solution that has been effective in the CIT Act since 1 January, 2022 and is intended to encourage investors to invest through Polish holding companies in other entities. In principle, the PHC allows for an exemption from taxation of dividend income paid by a Polish/foreign subsidiary to a…
Autumn has come and it has been followed by another changes in tax regulations, including the flat-rate income tax, or so-called withholding tax. Background to the changes The current version of the withholding tax regulations came into force on 1 January 2022. However, the fact that the legislator plans to amend the withholding tax rules…
The most important change concerning the minimum tax is the exemption of taxpayers from this tax in 2022 and 2023. For taxpayers whose fiscal year is different from the calendar year and starts before 1 January 2024 and ends after 31 December 2023, the exemption will apply until the end of that fiscal year. The…
The reform of Estonian CIT (sometimes called as “lump sum taxation”) under the Polish Deal, which began in 2022, allowed for a significant expansion of access to this form of taxation, e.g. by expanding the catalogue of entities eligible to apply Estonian CIT, reducing the flat rate on income, and abolishing the revenue limit. Thanks…