The Court of Justice of the European Union (CJEU) confirmed
What does it mean?
Cost segregation is a detailed identification of fixed assets based on tax regulations and Polish Fixed Assets Classification as well as determining the initial value of fixed assets including indirect costs.
Why is it worth it?
Depreciation of fixed assets
|Higher depreciation rates available.|
|Real Estate tax||Precisely defined structures to be taxed and their tax base. For an investment located in several communes, tax base is determined for each commune.|
|Preparing real estate (investment)|
|Transparent structure of fixed assets and better results in due diligence ordered by a buyer.|
|Inventory of property||Property review and the possibility of professional marking of fixed assets.|
|Real Estate clause|
In practice, it often turns out that after cost segregation the entity does not meet the definition of a real estate company and the clause does not apply.
|Fixed Assets||Initial value||Depreciation rate||Depreciation||Minimal CIT on Real Estate|
|Foundation for the turbine||100||4,50%||4,5||5|
|Turbine nacelle with generating set||250||7%||17,5||0|
|Blade and hub||200||7%||14||0|
Polish minimum corporate income tax (CIT) regulations will come into
One of the key elements of transfer pricing documentation is