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…
The Act of 6 November 2024 on Top-up Taxation of Constituent Entities of Multinational and Domestic Groups [GloBE Act] introduces a tax regime of minimum taxation of at least 15% of all group entities in one jurisdiction. Under the GloBE Act, constituent entities of domestic and multinational enterprise [MNE] groups – with consolidated revenues exceeding…
A number of significant and, in some cases, even revolutionary changes introduced in the tax legislation from 2025 require taxpayers to prepare carefully for their proper implementation. Particular attention is required to review the fixed asset records for real estate tax declarations and to adapt their classification to the new definitions. Taxpayers should also adapt…
Entrepreneurs operating in the IT industry can benefit from a wide range of tax reliefs and preferences aimed at supporting innovation and technological development. It is not surprising that so many solutions are dedicated to this fast-growing industry, given its key role in creating cutting-edge solutions for companies. Among the most popular tax instruments available…
Despite the wording of the provision on the condition of ‘being subject to tax’ sounds the same for dividends, interest and royalties, the MoF followed up its ruling on dividends by issuing an general tax ruling on this condition for interest and royalties (DD9.8202.2.2024). What is surprising is therefore its content This ruling also refers…
In recent days, the Ministry of Finance has published two general rulings relating to some of the conditions for the exemption from withholding tax of dividend and interest payments. These rulings are important, but are they groundbreaking? How will the existing practice of the authorities and courts change? In the first part, we are going…
Poland’s minimum income tax[1] may be particularly burdensome for the tobacco industry and international aircraft charter companies. What does this mean for entrepreneurs? The tobacco industry will not pay the minimum income tax For calculating the loss or level of profitability, no account shall be taken of revenue and tax-deductible costs directly or indirectly related…
The definition of ‘real estate company’ and the doubts related to it According to the regulations, a real estate company is an entity, other than a natural person, obliged to prepare a balance sheet on the basis of accounting regulations, in which at least 50% of the balance sheet value of the assets (or, in…