Refusals to issue security opinions on the application of General Anti-Abusive Regulations (GAAR)

The Head of National Revenue Administration (KAS) has completed more than 20 proceedings on the application of the General Anti-Abusive Regulations (GAAR). This resulted in the imposition of tax surcharges exceeding PLN 80M. We have written more on this subject here. What was challenged by the tax authorities? A spin-off of an organized part of […]

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 […]

On 11 June 2020 the Court of Justice of the European Union passed a significant ruling in the Portuguese case C-43/19 (Vodafone Portugal – Comunicações Pessoais SA)

The background of the case The object of Vodafone, a company established in Lisbon (Portugal), is the supply of electronic communications services, fixed telephony, and wireless internet access. In the context of its business activities, Vodafone concludes with its customers services contracts, some of which include special promotions subject to conditions that tie those customers […]

Begin typing your search term above and press enter to search. Press ESC to cancel.

Back To Top