Minister of Finance, General Interpretation No. DD8.8203.1.2021 Conclusions: Qualified costs for the R&D relief under Article 26e(2)(1) of the PIT Act and Article 18d(2)(1) of the CIT Act include payments...
Read More >CASES
TRANSFER PRICING
For one of the largest entity from the car manufacturing sector we prepared local transfer pricing documentation including benchmarking studies as well as group transfer pricing documentation for several tax years within a tight statutory deadline. The documentation was later used as part of the APA procedure in another EU Member State.
TAX LITIGATION
We assisted one foreign investor in Poland in their procedure of preparation for the tax dispute with the tax authorities regarding one selected year.
FINANCIAL MODELLING
For one of the largest capital groups we prepared a set of transactional benchmarking studies for intra-group agreements to be signed between the parties. The studies were made for transfer pricing purposes and intended to set the arm’s length price and protecting the board members from penal fiscal code liability in Poland.
CORPORATE INCOME TAX
The Client had faced a non-deductibility of the payments for services acquired by a service delivery center in Poland from its sister companies from abroad. A ruling was prepared to secure a more beneficial tax position.
INTERNATIONL TAX
For a regulated entity we developed a model of attribution of profit for the permanent establishment.
VALUATIONS
We assisted our Client in a corporate restructuring involving a hard-to-value intangible being transferred between the Company and its foreign branch – related party. We analyzed the possibilities to manage the tax income connected with the transfer. We verified the Client’s model and proposed our criteria for evaluation to be used for the discounted cash flow method.
TAX RELIEFS
For one of the most innovative high-tech companies in Poland we implemented intellectual property box regime which allowed to decrease their effective corporate income tax rate from 19% to 5%. The project involved deep analysis and understanding of the company’s value chain and the contribution of each team in the creation of IP.
VALUE ADDED TAX
We assisted our Client – a daughter company of an international group – in a tax dispute with the tax authority in regard to reimbursement of taxes paid. The financial function was outsourced and mistakes in the tax documentation were found by the previous accountant which caused a tax litigation procedure regarding to the tax points and tax reporting and prevented the Client to receive the reimbursement he expected.
ZT TAX BLOG
If your goal is to be up-do-date and have an overview of statutory tax deadlines and important changes in taxes in Poland before they happen, we invite you to read our posts.
The current legal definition of a “construction” for tax purposes is unconstitutional and must be changed
Constitutional Court, SK 14/21 Ruling: Article 1a (1)(2) of the Act of 12 January 1991 on Local Taxes and Fees is inconsistent with Article 84 and Article 217 of the...
Read More >