Polish residents cooperating with foreign contractors often receive an offer to participate in an incentive program, which provides for the free acquisition of stock options, and then transforming them into shares. The question arises whether the mere acquisition of an option generates taxable income in Poland? In the opinion of our Law Firm, this event, provided that certain conditions are met, does not allow for the recognition that it will be necessary to recognize tax revenue.
How did the legislator make it possible to use this legal and tax tool to reduce tax liabilities within the capital group? What is the impact of TCG on the freedom to make transactions between its related entities?
The purpose of the unilateral adjustment is to eliminate double taxation of related parties' income if the income of the domestic related party is included in the income of the foreign related party and (...)