Poland: Last call for taxpayers in Poland to review ATAD 2

Poland has implemented European Council Anti-Tax Avoidance Directive (ATAD 2) by introducing anti-hybrid provisions into its domestic law. The provisions apply starting from January 2021 and the taxpayers should take them into account in their 2021 CIT settlements and onwards. The deadline for the 2021 CIT return and CIT payment elapses on June 30 2022,…

Keep your arm’s-length distance – how to meet Polish TP obligations

Multinational companies that are familiar with transfer pricing (TP) issues in their countries might raise their eyebrows over the kinds of transactions that are subject to the arm’s-length rule in Poland. Usually, TP regulations apply to service, goods, and financial transactions made between related entities. Let’s go through the most controversial Polish regulations. #MORE on…

The absurdity of Polish TP obligations covering transactions with third parties

Participating in public consultations pays off! Eighteen months after the regulations came into force, the Ministry of Finance repealed the provisions on indirect tax haven transactions. Importantly, the obligations have also been cancelled for 2021. However, it should be remembered that transactions carried out directly with tax havens are still subject to reporting and documentation.…

Entrepreneurs benefiting from low lump-sum taxation in Poland

The Personal Income Tax Act defines business activity (BA) as a gainful activity conducted on one’s own behalf, irrespective of results, in an organised and continuous manner, from which the revenues are not attributed to other revenues from other sources, such as an employment relationship, managerial contracts, a director’s fee, or property rights. #MORE on…

Prospects for a global reform of the international taxation system

Conducting business activity within digital economy is subject to many specific regulations such as data protection or consumer protection. The necessity to adjust legal regulations to a dynamically changing business environment has also been observed in the tax world. Currently rules regarding the division of tax rights of multinationals firms doing business between different countries…