Both the provisions of the Corporate Income Tax (CIT) Act and the provisions of various double taxation treaties provide for the obligation to withhold tax on payments made to non-residents for the use of so-called “industrial equipment.” In principle, non-residents earning income in Poland from the use or right to use industrial equipment, including means…
What is the tax on income from buildings? The tax on income from buildings has been in effect in Polish law since January 1, 2018. This tax, commonly referred to as the “minimum tax on buildings,” is a solution designed to ensure effective taxation of entities operating in the real estate sector. Who is subject…
From the beginning of 2022, a provision limiting the amount of depreciation allowances made by real estate companies was introduced into the CIT Act. It allows depreciation write-offs on buildings and premises (group 1 of the NIT) to be recognised as tax deductible costs, but only up to the amount of balance sheet write-offs. Depreciation…
The tax on shifted income was intended to protect the Polish tax base from transfers income to tax havens. Initially, the regulations covered both domestic and cross-border payments, but after one year of being in force, the scope of the tax was limited to payments to non-residents only. This change has effectively become a time…
The list of countries that have obtained “qualified” status for GloBE purposes is now known. The Ministry of Finance published an announcement on February 7, 2025, regarding the list of non-Polish jurisdictions that have implemented a qualified income inclusion rule or a qualified domestic minimum top-up tax or meet the requirements for safe harbors for…
According to the wording of Article 15(6) of the CIT Act, in force since 2022, real estate companies may recognise depreciation write-offs on buildings and premises (group 1 of the Classification of Fixed Assets) as tax deductible costs, but only up to the amount of balance sheet write-offs. Since the amendment, real estate companies valuing…
The introduction of the domestic minimum top-up tax into Polish legal system is associated with the entry into force of the Act of 6 November 2024 (GloBE Act) on the top-up taxation for constituent entities of multinational and domestic groups. The GloBE Act introduces a regime for top-up taxation (at a minimum rate of 15%)…
The Act of 6 November 2024 on the top-up taxation of constituent entities of multinational and domestic groups (GloBE Act) introduces a global minimum tax system (at least 15%) at the jurisdiction level. Under the GloBE Act, entities belonging to multinational and domestic groups – with consolidated revenues exceeding €750 million in at least 2…
In 2025, WHT taxpayers will face some changes – among them, we will find new versions of the IFT-2R and CIT-10Z forms, concerning the foreign income of taxpayers earned from January 1, 2024. Comparing the new structure of the forms with the previous version will certainly make it easier to complete them, especially since many…
According to the presidential memorandum (dated January 20, 2025) directed to the Secretary of the Treasury and the U.S. Permanent Representative to the OECD, the United States is withdrawing from the Global Tax Deal. Therefore, the GloBE system will not apply in the United States. Does this mean that the GloBE system is no longer…