Please find below our brief summary: CIT/PIT Introduction of so-called minimal tax (amounting to 10% of tax basis) for companies and tax capital groups (i) which incurred operational loss or (ii) in case of which ratio of operational income to operational revenues does not exceed 1%; Decrease from 9% to 4.9% of non-deductible health insurance […]
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 […]
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 […]
Robotization relief – how to automate Polish entrepreneurs?
The Ministry of Finance plans to introduce tax relief for robotization and automation as of the second quarter of next year, at the latest in mid-2021. However, we are still waiting for a draft bill introducing this new solution. The main goals of the Polish legislator are: increase of the number of robots in industrial […]
Important amendments to CIT and PIT law in Poland
Please find below the most important changes which may affect your business in Poland: extending limited tax liability towards income from the sale of shares in real estate companies -> obligation of analysis of the structure of RE companies within 12 months prior to a transaction; partnerships (spółka komandytowa and spółka jawna in some cases) […]
CIT AND PIT IMPROVEMENT – LIMITED PARTNERSHIP COMPANY AS A CIT TAXPAYER
Limited partnerships are to become CIT taxpayers. This means that automatic compensation of income of one limited partnership with the loss incurred by another one at the level of partners of these entities will no longer be possible. Such structures will not be tax-effective anymore. This is the moment to consider other possibilities, to include […]
Poland – White List – new rules after 1 July 2020
The negative consequences of the White List register, introduced on 1 January 2020, regarding payments to the supplier’s bank account not included in the White List register for B2B (active VAT taxpayers) transaction over PLN 15 000 gross, result in: lack of the possibility to treat such an expense as tax-deductible cost in CIT and PIT, […]
Changes in taxes in Poland from 1 July 2020 – summary
Beginning from 1 July 2020 the following tax changes enter into force in Poland: Change of provisions concerning the so-called White List (resulting in changes in PIT, CIT and VAT) Making payments using a split payment mechanism (MPP) to a bank account not included in the White List does not generate a risk in income […]