Disposal of an organised part of an enterprise – what does it involve, what are the tax risks and how can they be secured?

Disposal of an organised part of an enterprise – what does it involve, what are the tax risks and how can they be secured?

Corporate tax, Trochę o CIT, Trochę o VAT, VAT

Organised part of an enterprise Tax regulations define an organised part of an enterprise [hereinafter: OPE] as a set of assets – tangible and intangible, including liabilities – organisationally and financially separated within an existing enterprise, intended to perform specific business tasks, which could also constitute an independent enterprise performing these tasks on its own.…

Repeated services provided by a partner in Estonian CIT

Corporate tax, Trochę o CIT

The tax authorities have changed their position on the so-called repeated non-monetary services provided by partners in limited liability companies with Estonian CIT, based on Article 176 of the Commercial Companies Code. Repeated benefits result from the shareholders’ obligation, specified in the articles of association, to perform activities of a remunerated and repetitive nature for…

Does a gratuitous guarantee under Estonian CIT mean no transfer pricing obligations?

Corporate tax, INSIGHT, Transfer pricing, Trochę o CIT

Does a gratuitous guarantee granted to a taxpayer subject to Estonian CIT by a related entity give rise to a transfer pricing documentation obligation? According to DKIS [1] – yes – if the value of the guarantee exceeds the threshold of PLN 10 million, the taxpayer will be required to prepare transfer pricing documentation.  …

Interpretative discrepancies of the KIS Director regarding the lease agreement between related entities on the Estonian CIT

Corporate tax, INSIGHT, Trochę o CIT

Recently issued individual interpretations indicate that tax authorities have inconsistent positions on the classification of lease or rental costs from related entities as so-called hidden profits. While the regulations remain consistent, the authorities’ positions are subject to variation depending on the specifics of each case. The following three approaches demonstrate the various perspectives of the…

Estonian CIT and transfer pricing

Corporate tax, INSIGHT, Trochę o CIT

Estonian CIT is an attractive form of taxation that can bring tangible tax benefits to companies. We discussed its advantages in more detail in our previous article: https://www.mddp.pl/zamkniecie-roku-dobry-czas-na-przejscie-na-cit-estonski/ In order to benefit from estonian CIT, taxpayers must meet certain conditions and operate in accordance with the principles of lump-sum taxation of corporate income. One of…