Polish order

Legal entity changes (CIT)

  • clarification of the issue of tax residence
  • waiver of the limit for qualifying intangible services as tax deductible costs
  • costs of debt financing obtained from a related entity are not deductible in the relevant part
  • The following are NOT subject to depreciation: cooperative ownership right to a flat, right to a single-family house in a housing cooperative
  • costs of benefits, the beneficiary of which is a partner or entity related to the taxpayer or partner, are excluded from tax costs (the so-called hidden dividend)
  • new tax breaks - trial production, robotization, IPO
  • IP BOX and R&D relief can be used together
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  • minimum 10% income tax
  • tax on "shifted income"
  • changes in withholding tax (WHT)
  • abolition of the obligation to incur capital expenditures to apply the "Estonian CIT"
  • extension of the catalog of entities authorized to use the "Estonian CIT" to include limited partnerships and limited joint-stock partnerships
  • extending the directory of income from capital gains
  • changes related to the creation and operation of tax capital groups (PGK)
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  • detailed analysis of the client's situation
  • tax and legal advice on the application of changes and new client obligations from 2022
  • tax and legal advice in the context of a selected change / several selected changes in force from 2022
  • identification of the client's tax risks
  • tax planning
  • identification of scenarios of proceedings
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Transfer prices

  • introducing the institution of an investment agreement and a tax agreement
  • new extended deadlines for the preparation of documentation and submission of TPR information
  • introducing new exemptions from the obligation to prepare documentation
  • exemption from the obligation to prepare a benchmark for selected entities and groups of transactions
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  • the need to re-analyze the transactions carried out
  • the need to re-analyze potential risks related to the company's operations
  • the need to re-analyze the taxpayer's transfer pricing obligations
  • change of the work schedule related to the preparation of transfer pricing documentation and submission of TPR information
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  • identification of what changes may affect your company
  • analysis of the client's obligations in the light of the proposed changes to the regulations
  • estimating the risk and potential
  • legal and tax advice in the field of economic strategy
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Other changes

  • limit for cash transactions reduced from PLN 15,000 to PLN 8,000
  • obligation to introduce payments using a payment instrument for certain groups of entrepreneurs
  • change of the definition of the beneficial owner
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  • creation of VAT groups
  • taxation of financial transactions
  • the possibility of taxing undisclosed income with a transitional lump sum of 8% at the taxpayer's request
  • increased burden on public law contractors (B2B) - higher health insurance premium - may result in pressure to renegotiate contracts
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  • detailed analysis of the client's situation
  • tax and legal advice on the application of changes and new client obligations from 2022
  • tax and legal advice in the context of a selected change / several selected changes in force from 2022
  • tax planning
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Polish order of law

  • identify what changes may affect your company
  • assess the risks and potential opportunities
  • use the help of professional advisers
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  • remember that the consequences of introducing tax changes will be recognizable only after the end of the legislative process
  • it will take place at the turn of November and December 2021.
  • the vast majority of the changes are to enter into force from 2022.
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