General Anti-Abusive Regulations (GAAR) were introduced in Poland as of 15 July 2016. However, for the first 3 years, they were scarcely used. This has however changed. In the press publications of 16 October 2020, the Ministry of Finance informs that he has just finished 20 tax proceedings which resulted in PLN 500M of additional taxable […]
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 […]
Tax authorities apply General Anti-Avoidance Rules
Recent information published by the Ministry of Finance shows how the tax authorities are making use of the General Anti-Avoidance Regulations (GAAR) and provide details of opinions recently issued by the Council for Prevention of Tax Avoidance, which is in Polish Rada do spraw przeciwdziałania unikaniu opodatkowania (“Council”). We note that the Council has been […]