No CFC for Tax Transparent Entity

This is the end of the 5-year CFC dispute. The Supreme Administrative Court finally confirmed what we have argued for from the beginning: that income derived by a tax transparent partnership should be considered business activity income aid, in consequence, non-passive income on the grounds of the CFC regulations. What was the background of the dispute?  Some time ago the tax authorities came to the conclusion that it would be good to cut all the discussions and […]

R&D and IP Box relief in the latest tax interpretations

The Director of the National Tax Information (Director of KIS) has recently issued several significant individual tax rulings concerning R&D tax relief for taxpayers creating innovative solutions and preferential taxation of income from qualified intellectual property rights (IP Box relief). These rulings are related i.a. to conditions of recognizing specific categories of costs as qualifying […]

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