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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 […]

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 […]

Investing in Poland from the level of the Netherlands or through a Dutch holding company is becoming more and more troublesome

First of all, there are significant anti-abusive provisions upcoming in the local Polish and Dutch regulations as of 2021: new business substance requirements for service companies in the Netherlands – minimum EUR 100k of annual wage expenses, office space for the period of 2 years; introduction on WHT on interest and royalties paid from DutchCo […]

Polish Minister of Finance explanations on cash register receipts classified as simplified invoices

The possibility of issuing simplified invoices (so-called receipt with TIN) was introduced in 2013 and since then many taxpayers’ doubts have grown around them. Recent changes to regulations and growing doubts as to their application have prompted the Minister of Finance (MF) to issue on 20 October 2020 tax clarifications in this regard. A simplified […]

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 […]

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