The Director of the National Fiscal Information (so-called Director of KIS) issued an individual tax ruling with the reference no 0111-KDIB2-1.4010.128.2022.2.AR, confirming the possibility to apply the withholding tax exemption for dividends paid to a foreign holding company. According to the position of the Director of KIS, the look-through approach may be applied to verify […]
Minimum income tax more taxpayer-friendly
The minimum income tax, introduced in the CIT Act as of January 1, 2022, from the beginning has raised doubts and controversy among taxpayers. Recently, however, there has been hope for business conducted in Poland to change the unfavorable regulations. The Minister of Finance has published a draft law that postpones the application of the […]
Regulations on hidden dividend will be lifted
The Minister of Finance has presented a draft amendment to the CIT Act that repeals the so-called hidden dividend regulations. The provisions, aimed to counteract aggressive tax optimisation, were due to come into force on 1 January 2023. However, according to the MF’s draft, they will repealed from the CIT Act before they came into […]
Changes in CIT Act
A proposition of amended CIT regulations was presented by Ministry of Finance. As of 1 January 2023, the planned changes are about to come into force. Withdrawal of “hidden dividend” regulations One of the most important changes is withdrawal of hidden dividend regulations which was to be introduced within Polish Deal 1.0. Hidden dividend means […]
Polish Deal 2.0 – Tax changes from 1 July 2022
Tax changes introduced as of 1 January 2022 (the so-called Polish Deal) have caused major uncertainties when calculating salaries for employees. For this reason, the Ministry of Finance decided to introduce new legislation which aims at simplifying tax settlements. Tax changes are already in force and will apply to settlements as of the beginning of […]
The obligatory KSeF as of 2024
The EU draft decision issued on June 10, 2022, says that the obligatory KSeF will be implemented in Poland from 2024 at the earliest. What’s important? the obligation of electronic invoicing will cover all transactions made by taxpayers based in Poland, which currently require issuing an invoice in accordance with the Polish VAT Act; the […]
Branches of foreign entities in Poland – get ready for the difficulties
The approach of Polish tax authorities to the status of branches of foreign entities in Poland is very specific and causes a lot of confusion not only for taxpayers but also for the tax authorities themselves. Below you will find a short summary of what foreign entities may expect when establishing a branch in Poland. […]
Changes in CFC regulations
We would like to bring your attention to new CFC (Controlled Foreign Companies) regulations which were passed by the parliament and will probably take effect as of 2022 CFC reconciliations: Extension of the definition of a foreign entity for CFC purposes (earlier: share in equity, profit or participation in company’s bodies of related parties of […]
The New Polish Deal focuses on innovation – tax relief for entrepreneurs
The government’s development plan will soon become a new Polish reality. Thus, it is worth paying special attention to the extended package of tax reliefs that can be used at every stage of the production process. The proposed solutions are primarily aimed at increasing support for R&D activities in Poland. Simultaneous R&D and IP Box […]
What has changed in the “Polish New Deal” package in comparison to its initial version?
Please find below our brief summary: CIT/PIT Introduction of so-called minimal tax (amounting to 10% of tax basis) for companies and tax capital groups (i) which incurred operational loss or (ii) in case of which ratio of operational income to operational revenues does not exceed 1%; Decrease from 9% to 4.9% of non-deductible health insurance […]