A new innovation package for entrepreneurs

A draft of the tax act has been published to introduce a tax relief system for companies in CIT and PIT. The system of reliefs is intended to encourage entrepreneurs to innovations and will include the following elements: research and development relief supporting works on a new product, service, or process; relief for employing innovative […]

Repatriation Program

The Ministry of Finance presented details of the so-called Repatriation Program, which aims at (i) encouraging Polish citizens to return to Poland and (ii) creating favorable conditions for investments and family business in Poland. Below we present the main assumptions of the Program. Relief for return Individuals living and working abroad for at least 3 […]

WHT regime postponement in Poland

On 11 June 2021 draft regulations introducing the postponement (for the sixth time!) of the mandatory WHT pay-and-refund regime until 31 December 2021 were published on the RCL website. As the Ministry of Finance clarifies, the postponement results from the exceptional conditions of the COVID-19 pandemic, which makes it unreasonable to burden payers and taxpayers […]

New reporting obligation for a specific task contract (umowa o dzieło) as of 1 January 2021

The amendment to the “COVID-19 Act” dated March 31, 2020, introduced an additional obligation for companies engaging individuals under specific task contracts (umowa o dzieło). As of January 1, 2021, a remitter (Polish company) will be obliged to inform Social Insurance Institution (ZUS) of the conclusion of each specific task contract, provided that: the contract […]

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 […]

Minister of Finance’s general ruling on a 50% rate of the tax-deductible cost of revenues for authors

According to the recently published general ruling of the Minister of Finance, tax-deductible costs connected with the use of copyright by authors and performers of related rights amount to 50% of revenue. These costs are calculated on income reduced by social security contributions. The ruling indicates the conditions under which it is possible to apply […]

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