Changes in Polish corporate income tax 2020. On 23rd of September our experts: Marcin Jaworski and Michał Jagielski summarized biggest corporate income tax challenges and opportunities for 2020.
More info: https://pwc.to/2lkTbOj
Planned changes to Polish corporate income tax (CIT) law in 2021 include:
1) Taxation of limited partnerships and taxation of limited partners similar to shareholders of capital companies.
2) Introduction of "Estonian CIT" which allows companies to not pay tax until profits are distributed and provides other benefits to promote investment.
3) Changes to the definition of "real estate company" and new mechanisms for taxing sales of shares in real estate companies.
4) Additional reporting requirements and public disclosure of tax data for some real estate companies.
Polish CIT in 2019 - CIT and TP revolution marches onPwC Polska
This document summarizes changes to Poland's corporate income tax (CIT) and transfer pricing regulations in 2019. Key changes include:
1. Reduction of transfer pricing documentation duties for small and medium enterprises. New materiality thresholds were introduced for transfer pricing documentation.
2. Simplification of tax duties around transfer pricing documentation including extended deadlines, ability to submit documents in English, and new exemptions.
3. Revisions to Poland's approach to the arm's length principle including the ability of tax authorities to recharacterize or disregard related party transactions.
4. Introduction of an "IP box" tax regime with a 5% tax rate on qualified income from intellectual property rights like patents held in Poland
If a company in Poland sells goods to customers in the UK after the Brexit transition period ends, it will be treated as an export from the EU and import into the UK. Both the Polish supplier and UK customer will need EORI numbers and may need to make customs declarations and pay import duties and VAT. The Polish supplier may need to register for UK VAT and set up UK VAT and Intrastat compliance processes. Both companies will likely need to adapt their ERP systems to handle the new cross-border trade flows and formalities. The allocation of responsibilities will depend on the delivery terms agreed between the parties.
Poland as a digital pioneer in challenging tax fraudPwC Polska
The document provides information about Poland's implementation of Standard Audit File for Tax (SAF-T) reporting and a split payment mechanism for VAT.
It discusses how SAF-T reporting is now mandatory for Polish taxpayers on a monthly basis and includes data from VAT registers, invoices, accounting books, and other tax-related records in a standardized XML format. Non-compliance can result in fines up to 3 million PLN. The tax authorities use SAF-T data to identify discrepancies and select taxpayers for audit.
It also outlines Poland's proposed voluntary and automatic split payment mechanism for VAT. This would involve banks dividing VAT payments for business transactions into separate amounts for the net value and VAT, paid into different
It has been 18 months since the introduction of the clause on settling doubts to the benefit of tax payers. Its aim was to change the approach of tax authorities towards companies and citizens. Unfortunately, it turned out that the clause has not been applied.
Planned changes to Polish corporate income tax (CIT) law in 2021 include:
1) Taxation of limited partnerships and taxation of limited partners similar to shareholders of capital companies.
2) Introduction of "Estonian CIT" which allows companies to not pay tax until profits are distributed and provides other benefits to promote investment.
3) Changes to the definition of "real estate company" and new mechanisms for taxing sales of shares in real estate companies.
4) Additional reporting requirements and public disclosure of tax data for some real estate companies.
Polish CIT in 2019 - CIT and TP revolution marches onPwC Polska
This document summarizes changes to Poland's corporate income tax (CIT) and transfer pricing regulations in 2019. Key changes include:
1. Reduction of transfer pricing documentation duties for small and medium enterprises. New materiality thresholds were introduced for transfer pricing documentation.
2. Simplification of tax duties around transfer pricing documentation including extended deadlines, ability to submit documents in English, and new exemptions.
3. Revisions to Poland's approach to the arm's length principle including the ability of tax authorities to recharacterize or disregard related party transactions.
4. Introduction of an "IP box" tax regime with a 5% tax rate on qualified income from intellectual property rights like patents held in Poland
If a company in Poland sells goods to customers in the UK after the Brexit transition period ends, it will be treated as an export from the EU and import into the UK. Both the Polish supplier and UK customer will need EORI numbers and may need to make customs declarations and pay import duties and VAT. The Polish supplier may need to register for UK VAT and set up UK VAT and Intrastat compliance processes. Both companies will likely need to adapt their ERP systems to handle the new cross-border trade flows and formalities. The allocation of responsibilities will depend on the delivery terms agreed between the parties.
Poland as a digital pioneer in challenging tax fraudPwC Polska
The document provides information about Poland's implementation of Standard Audit File for Tax (SAF-T) reporting and a split payment mechanism for VAT.
It discusses how SAF-T reporting is now mandatory for Polish taxpayers on a monthly basis and includes data from VAT registers, invoices, accounting books, and other tax-related records in a standardized XML format. Non-compliance can result in fines up to 3 million PLN. The tax authorities use SAF-T data to identify discrepancies and select taxpayers for audit.
It also outlines Poland's proposed voluntary and automatic split payment mechanism for VAT. This would involve banks dividing VAT payments for business transactions into separate amounts for the net value and VAT, paid into different
It has been 18 months since the introduction of the clause on settling doubts to the benefit of tax payers. Its aim was to change the approach of tax authorities towards companies and citizens. Unfortunately, it turned out that the clause has not been applied.
HWC competence brochure - Tax & Accounting in UkraineSven Henniger
Specific of the Ukrainian Market
Accounting in Ukraine
Main Taxes in Ukraine
Start-Up Cost
International Payments
Payments in Foreign Currency
Corporate Profit Tax
Value Added Tax
Personal Income Tax
Unified Social Security Contribution
Military Tax
Simplified Taxation System (Single Tax)
Cash Payments
Foreign Currency Transaction
Licensing
Transfer Pricing
Personnel Administration
Options to Finance Ukrainian Subsidiaries
*10.2015
This document summarizes the current Swiss regulatory environment for not-for-profit organizations. It discusses recent developments in tax exemption laws, case law on tax exemption revocation, VAT reform increasing registration thresholds, changes to deducting input VAT, and disclosure of board member compensation. It also covers regulations around money laundering, classification of NPOs for tax information exchange, and implications of the EU's General Data Protection Regulation for Swiss NPOs.
This document discusses provisions around migrating existing taxpayers to the GST regime and carrying forward credits from prior tax systems. It states that persons registered under existing laws and with a PAN will be issued a provisional GST registration certificate. It also allows the carrying forward of credits for taxes like central excise duty, VAT, and service tax held in electronic ledgers to the GST system. It provides conditions for claiming credits on stocks held and specifies eligible credits that can be carried forward. It also discusses provisions for availing unutilized capital goods credits under GST.
This document discusses the requirements for output tax invoices and input tax invoices under Indonesian tax law. It notes that tax invoices must contain specific information like the names and addresses of the buyer and seller, a description of goods/services, prices, taxes collected, and authorized signatures. Tax invoices must be issued either at delivery, receipt of payment, or receipt of a partial payment term. Considerations for issuing tax invoices include meeting legal requirements, timely issuance, and payment terms to prevent VAT losses. Material requirements are met if the tax invoice information clearly matches the actual transaction details.
The document summarizes some key changes introduced by Romania's new Tax Procedure Code:
1) It establishes the principle of in dubio contra fiscum, requiring tax authorities to interpret ambiguous tax rules in favor of taxpayers, though in practice this may offer limited protection.
2) It clarifies rules around resuming tax inspections, allowing inspections to continue even if the statute of limitations has expired.
3) It introduces a new non-declaration penalty that is controversial and may effectively increase penalties on taxpayers who disagree with tax authorities' interpretations in good faith.
Through the Fiscal Bulletin sent on September 4, 2017, we announced the introduction of the VAT split payment mechanism by Government Ordinance No. 23/2017. After the Ordinance passed the Parliament approval through a law and the Approval Law was published in the Official Gazette, the VAT split payment mechanism has undergone major changes – in a positive way for most taxpayers.
This document discusses the changes to service tax laws in India that took effect on July 1, 2012, moving from a positive list system to a negative list system. Key points include:
1) Service tax coverage was expanded by defining "service" and taxing all services except those specified in a negative list of exemptions.
2) The number of taxable services was reduced and definitions were simplified compared to the previous system which had over 100 taxable services.
3) A works contract is taxable only on the service portion, with set valuations to determine this portion.
4) Certain services involve reverse charge mechanism where the liability shifts entirely or partially to the service recipient.
5)
With VAT implementation taking effect in under six months, the Ministry of Finance have now provided further clarification of the rules which will be imposed in respect of VAT within the UAE, furthermore we have seen updates across Saudi Arabia recently, with announcements being made in respect of the registration process. This short alert from Grant Thornton UAE summarises the recent clarifications which the UAE have announced, alongside the registration elements required within Saudi Arabia.
Taxes in Ukraine 2021 by DLF law firm in UkraineChristine Khariv
General information on tax rates, objects and bases of taxation in Ukraine, as well as peculiarities of taxation of certain categories of taxpayers, in particular, non-residents.
Compilation of FTA Clarifications & User Guides by manoj agarwalManoj Agarwal
ebook is a compilation of all the Clarifications and User Guides issued by Federal TAx Authority "FTA" related with UAE VAT Law and Executive Regulations.
The document provides instructions for submitting a request for a letter ruling from the New York City Department of Finance. A $250 processing fee and completed request form are required for all requests. A letter ruling sets forth how statutory tax provisions apply to a specific set of facts. General tax information may be available without a ruling. The Department will not issue rulings on matters under audit or clearly addressed elsewhere. Requests must include facts and documents to be considered.
This document provides frequently asked questions about VAT implementation in GCC countries. It discusses what VAT is, how it is calculated and applied, preparations businesses need to make for compliance, and expectations of tax authorities. It also addresses questions related to SAP solutions for VAT computation, legal reporting, timelines, and how customers can stay updated on releases. SAP plans to support VAT compliance through country templates, a tax calculation service, legal reporting tools in S/4HANA and SAP Cloud Platform, and will update solutions once VAT laws are declared.
1 UK VAT refunds for non-EU businesses require action by 31 December 2015TIAG_Alliance
Executive Summary
Many multinational enterprises (MNEs) incur VAT in countries where they are not established or VAT registered. A business may, for example, incur foreign VAT on trade fairs and conferences, meals and accommodations, travel, transportation and fuel costs, business entertainment, marketing and advertising costs, professional services, telecommunications; printing materials and stationery, and training.
Non-EU businesses that have incurred value added tax (VAT) in the UK during the 12 month period July 2014-June 2015 may be able to recover the VAT by applying for a refund - provided they comply with the rules. Claims by non-EU businesses must be submitted within six months following the end of the claim period. The closing date for applications for the above 12 month period is 31st December 2015, so taxpayers should be collecting the required information now to support a successful claim. The deadline is a fixed date, and late claims are not accepted. The fact claims are made by post and the deadline follows shortly after the Christmas holiday period needs to be borne in mind.
The document discusses various taxes in accounting including income tax, sales tax, and value-added tax (VAT). It provides details on income tax slabs for salaried individuals, how to maintain income tax withholding on goods and services, the liability and rates of sales tax, and defines VAT. The key information covered includes different categories of taxpayers for income tax, the responsibilities of withholding agents to deduct and deposit taxes, and the requirements for registered entities to file tax returns and maintain records.
This chapter from the textbook Intermediate Accounting discusses accounting for income taxes. It covers differences between pre-tax financial income and taxable income, temporary and permanent differences that result in future taxable or deductible amounts, deferred tax assets and liabilities, applying tax rates, net operating losses, and the asset-liability method for income tax accounting. The chapter is prepared by Jep Robertson and Renae Clark of New Mexico State University.
1. China will adopt the OECD's Automatic Exchange of Financial Account Information standard to enhance international tax cooperation and transparency.
2. Under this standard, Chinese financial institutions will identify accounts held by non-residents, collect and report account information to Chinese tax authorities, which will automatically exchange this information with tax authorities in other countries.
3. The consultation paper provides details on the due diligence procedures financial institutions must follow to identify reportable accounts, the timeline for implementation, and the types of financial account information that will be reported and exchanged.
US Tax Reform: The Potential Tax Implications for Brazilian TaxpayersRamon Tomazela
In this article, the author analyses the main corporate tax reform proposals under discussion in the United States
and their potential implications for Brazilian taxpayers.
Grant Thornton Hungary Tax News - November 2014 en (2)Alex Baulf
Tax Service News from Grant Thornton Hungary:
Grant Thornton Hungary would like to call your attention to the most important tax law changes. Most of the changes will enter into force by 1 January 2015. We indicate separately, if legislation enters into force at a different date.
The information provided herein is of general nature and is based on facts subject to change. Such information may not be regarded and therefore in no way interpreted as accountancy, legal or taxation advice provided to the reader by Grant Thornton Hungary. These materials are not aimed at complying with particular scenarios and to be suitable for application in certain situations, therefore the consideration of certain taxation law and other factors not
discussed herein may be necessary. With regard to this – should you resolve upon any action whatsoever based on the information provided herein – it is recommended to establish contact with Grant Thornton Hungary or other taxation specialists. Amendments of the taxation laws and other factors may influence the contents communicated herein – in certain cases even with retroactive effect. Grant Thornton Hungary assumes no responsibility of informing the readers of these changes.
ALBANIA Chinese citizens excluded from Type C Visa regime
Fiscal package 2020 in Albania
Tax Procedures in Albania 2020
Value Added Tax 2020
Albania Personal And Profit Tax 2020
Albania National Taxes 2020
ALBANIA TAX FREE Real Estate Donation to Family Members 2020
VIETNAM TAXATION – OUTLOOK ON THE EUROPEAN UNION VIETNAM FREE TRADE AGREEMENT...Dr. Oliver Massmann
The document discusses several issues with Vietnam's taxation system and opportunities presented by the EU-Vietnam Free Trade Agreement (EVFTA). It identifies inconsistencies between central government policies and local tax department practices, contradictory regulations, and complexity in VAT calculation and refund rules that create difficulties for businesses. Implementation of clearer rules and guidelines is needed to resolve tax payment issues, properly apply incentives, and avoid penalties from changing interpretations. The EVFTA is expected to boost investment and trade but also influence Vietnam to adopt more fixed and determined tax rules for greater certainty.
HWC competence brochure - Tax & Accounting in UkraineSven Henniger
Specific of the Ukrainian Market
Accounting in Ukraine
Main Taxes in Ukraine
Start-Up Cost
International Payments
Payments in Foreign Currency
Corporate Profit Tax
Value Added Tax
Personal Income Tax
Unified Social Security Contribution
Military Tax
Simplified Taxation System (Single Tax)
Cash Payments
Foreign Currency Transaction
Licensing
Transfer Pricing
Personnel Administration
Options to Finance Ukrainian Subsidiaries
*10.2015
This document summarizes the current Swiss regulatory environment for not-for-profit organizations. It discusses recent developments in tax exemption laws, case law on tax exemption revocation, VAT reform increasing registration thresholds, changes to deducting input VAT, and disclosure of board member compensation. It also covers regulations around money laundering, classification of NPOs for tax information exchange, and implications of the EU's General Data Protection Regulation for Swiss NPOs.
This document discusses provisions around migrating existing taxpayers to the GST regime and carrying forward credits from prior tax systems. It states that persons registered under existing laws and with a PAN will be issued a provisional GST registration certificate. It also allows the carrying forward of credits for taxes like central excise duty, VAT, and service tax held in electronic ledgers to the GST system. It provides conditions for claiming credits on stocks held and specifies eligible credits that can be carried forward. It also discusses provisions for availing unutilized capital goods credits under GST.
This document discusses the requirements for output tax invoices and input tax invoices under Indonesian tax law. It notes that tax invoices must contain specific information like the names and addresses of the buyer and seller, a description of goods/services, prices, taxes collected, and authorized signatures. Tax invoices must be issued either at delivery, receipt of payment, or receipt of a partial payment term. Considerations for issuing tax invoices include meeting legal requirements, timely issuance, and payment terms to prevent VAT losses. Material requirements are met if the tax invoice information clearly matches the actual transaction details.
The document summarizes some key changes introduced by Romania's new Tax Procedure Code:
1) It establishes the principle of in dubio contra fiscum, requiring tax authorities to interpret ambiguous tax rules in favor of taxpayers, though in practice this may offer limited protection.
2) It clarifies rules around resuming tax inspections, allowing inspections to continue even if the statute of limitations has expired.
3) It introduces a new non-declaration penalty that is controversial and may effectively increase penalties on taxpayers who disagree with tax authorities' interpretations in good faith.
Through the Fiscal Bulletin sent on September 4, 2017, we announced the introduction of the VAT split payment mechanism by Government Ordinance No. 23/2017. After the Ordinance passed the Parliament approval through a law and the Approval Law was published in the Official Gazette, the VAT split payment mechanism has undergone major changes – in a positive way for most taxpayers.
This document discusses the changes to service tax laws in India that took effect on July 1, 2012, moving from a positive list system to a negative list system. Key points include:
1) Service tax coverage was expanded by defining "service" and taxing all services except those specified in a negative list of exemptions.
2) The number of taxable services was reduced and definitions were simplified compared to the previous system which had over 100 taxable services.
3) A works contract is taxable only on the service portion, with set valuations to determine this portion.
4) Certain services involve reverse charge mechanism where the liability shifts entirely or partially to the service recipient.
5)
With VAT implementation taking effect in under six months, the Ministry of Finance have now provided further clarification of the rules which will be imposed in respect of VAT within the UAE, furthermore we have seen updates across Saudi Arabia recently, with announcements being made in respect of the registration process. This short alert from Grant Thornton UAE summarises the recent clarifications which the UAE have announced, alongside the registration elements required within Saudi Arabia.
Taxes in Ukraine 2021 by DLF law firm in UkraineChristine Khariv
General information on tax rates, objects and bases of taxation in Ukraine, as well as peculiarities of taxation of certain categories of taxpayers, in particular, non-residents.
Compilation of FTA Clarifications & User Guides by manoj agarwalManoj Agarwal
ebook is a compilation of all the Clarifications and User Guides issued by Federal TAx Authority "FTA" related with UAE VAT Law and Executive Regulations.
The document provides instructions for submitting a request for a letter ruling from the New York City Department of Finance. A $250 processing fee and completed request form are required for all requests. A letter ruling sets forth how statutory tax provisions apply to a specific set of facts. General tax information may be available without a ruling. The Department will not issue rulings on matters under audit or clearly addressed elsewhere. Requests must include facts and documents to be considered.
This document provides frequently asked questions about VAT implementation in GCC countries. It discusses what VAT is, how it is calculated and applied, preparations businesses need to make for compliance, and expectations of tax authorities. It also addresses questions related to SAP solutions for VAT computation, legal reporting, timelines, and how customers can stay updated on releases. SAP plans to support VAT compliance through country templates, a tax calculation service, legal reporting tools in S/4HANA and SAP Cloud Platform, and will update solutions once VAT laws are declared.
1 UK VAT refunds for non-EU businesses require action by 31 December 2015TIAG_Alliance
Executive Summary
Many multinational enterprises (MNEs) incur VAT in countries where they are not established or VAT registered. A business may, for example, incur foreign VAT on trade fairs and conferences, meals and accommodations, travel, transportation and fuel costs, business entertainment, marketing and advertising costs, professional services, telecommunications; printing materials and stationery, and training.
Non-EU businesses that have incurred value added tax (VAT) in the UK during the 12 month period July 2014-June 2015 may be able to recover the VAT by applying for a refund - provided they comply with the rules. Claims by non-EU businesses must be submitted within six months following the end of the claim period. The closing date for applications for the above 12 month period is 31st December 2015, so taxpayers should be collecting the required information now to support a successful claim. The deadline is a fixed date, and late claims are not accepted. The fact claims are made by post and the deadline follows shortly after the Christmas holiday period needs to be borne in mind.
The document discusses various taxes in accounting including income tax, sales tax, and value-added tax (VAT). It provides details on income tax slabs for salaried individuals, how to maintain income tax withholding on goods and services, the liability and rates of sales tax, and defines VAT. The key information covered includes different categories of taxpayers for income tax, the responsibilities of withholding agents to deduct and deposit taxes, and the requirements for registered entities to file tax returns and maintain records.
This chapter from the textbook Intermediate Accounting discusses accounting for income taxes. It covers differences between pre-tax financial income and taxable income, temporary and permanent differences that result in future taxable or deductible amounts, deferred tax assets and liabilities, applying tax rates, net operating losses, and the asset-liability method for income tax accounting. The chapter is prepared by Jep Robertson and Renae Clark of New Mexico State University.
1. China will adopt the OECD's Automatic Exchange of Financial Account Information standard to enhance international tax cooperation and transparency.
2. Under this standard, Chinese financial institutions will identify accounts held by non-residents, collect and report account information to Chinese tax authorities, which will automatically exchange this information with tax authorities in other countries.
3. The consultation paper provides details on the due diligence procedures financial institutions must follow to identify reportable accounts, the timeline for implementation, and the types of financial account information that will be reported and exchanged.
US Tax Reform: The Potential Tax Implications for Brazilian TaxpayersRamon Tomazela
In this article, the author analyses the main corporate tax reform proposals under discussion in the United States
and their potential implications for Brazilian taxpayers.
Grant Thornton Hungary Tax News - November 2014 en (2)Alex Baulf
Tax Service News from Grant Thornton Hungary:
Grant Thornton Hungary would like to call your attention to the most important tax law changes. Most of the changes will enter into force by 1 January 2015. We indicate separately, if legislation enters into force at a different date.
The information provided herein is of general nature and is based on facts subject to change. Such information may not be regarded and therefore in no way interpreted as accountancy, legal or taxation advice provided to the reader by Grant Thornton Hungary. These materials are not aimed at complying with particular scenarios and to be suitable for application in certain situations, therefore the consideration of certain taxation law and other factors not
discussed herein may be necessary. With regard to this – should you resolve upon any action whatsoever based on the information provided herein – it is recommended to establish contact with Grant Thornton Hungary or other taxation specialists. Amendments of the taxation laws and other factors may influence the contents communicated herein – in certain cases even with retroactive effect. Grant Thornton Hungary assumes no responsibility of informing the readers of these changes.
ALBANIA Chinese citizens excluded from Type C Visa regime
Fiscal package 2020 in Albania
Tax Procedures in Albania 2020
Value Added Tax 2020
Albania Personal And Profit Tax 2020
Albania National Taxes 2020
ALBANIA TAX FREE Real Estate Donation to Family Members 2020
VIETNAM TAXATION – OUTLOOK ON THE EUROPEAN UNION VIETNAM FREE TRADE AGREEMENT...Dr. Oliver Massmann
The document discusses several issues with Vietnam's taxation system and opportunities presented by the EU-Vietnam Free Trade Agreement (EVFTA). It identifies inconsistencies between central government policies and local tax department practices, contradictory regulations, and complexity in VAT calculation and refund rules that create difficulties for businesses. Implementation of clearer rules and guidelines is needed to resolve tax payment issues, properly apply incentives, and avoid penalties from changing interpretations. The EVFTA is expected to boost investment and trade but also influence Vietnam to adopt more fixed and determined tax rules for greater certainty.
VIETNAM TAX ISSUES – OUTLOOK ON THE EUROPEAN UNION VIETNAM FREE TRADE AGREEME...Dr. Oliver Massmann
The document discusses several issues related to Vietnam's tax system and opportunities under the EU-Vietnam Free Trade Agreement (EVFTA). It notes inconsistencies in how local tax departments apply tax incentives for businesses and calls for clearer guidance. It also points out complexities for enterprises in complying with the declarations and incentives across different documents. Additionally, it raises concerns about discrimination in value-added tax refunds for businesses with output VAT at 5% compared to exporters. Overall, it advocates for simplifying regulations and ensuring fair and consistent treatment of businesses under Vietnam's tax system.
Webinar important tax changes in poland from 2022 the polish deal (7.12)PwC Polska
The document provides an agenda and overview for PwC Poland's webinar on important tax changes in Poland from 2022, known as "The Polish Deal". The webinar will cover an overview of the Polish Deal, its impact on investors, international tax and transfer pricing changes, and personal income tax implications. Specific sessions will discuss the Polish Deal's effect on CIT, PIT, tax incentives, and other changes to the Polish tax law.
vat implementing regulations for public consultationSwamy Nlnj
The Saudi Arabian Tax Authority has released draft VAT implementing regulations for public consultation, with VAT to be implemented on January 1, 2018. The standard VAT rate will be wide in scope with few exemptions. Key provisions in the draft regulations include registration requirements, VAT grouping rules, taxable financial services, exemptions for residential leasing and medical supplies, rules for government entities, and documentation requirements for invoices, returns, and record keeping. Businesses should assess the VAT impact and prepare compliance plans across key areas like finance, supply chain, and IT systems.
TCG_Newsletter_January and February 2019_EnTham Le
Welcome to our newsletter in January and February 2019. You will find that it is filled with legal regulations in certain areas of business.
We hope this newsletter to keep you updated on the latest legal news and be valuable to your operation.
Thanks for your reading and we would love to hear your comments that could make our reports better and better.
This document summarizes key aspects of Poland's tax system according to a 2016 brochure by Baker & McKenzie. It outlines the corporate income tax rate of 19%, personal income tax rates ranging from 18-32%, and a standard VAT rate of 23% with some reduced rates. It also discusses social security contributions that are split between employers and employees, as well as other taxes such as tax on civil law transactions and real estate tax.
On 2 December 2016 the Law Decree 22 October 2016 n. 193 (“Tax decree”) completed its legislative process with the publication in the Official Gazette of the consolidated text, post amendments, occurred at the time of the conversion into Law. Some of the adopted measures are a way to implement the new strategy of the Tax Administration to prevent tax evasion and to reduce the VAT gap. Most of the measures have the aim to modernize the way in which taxable persons accomplish VAT fulfillments, so that these latter can be more effective, leveraging on an intense use of electronic means. Grant Thornton Italy summarize in this VAT Alert, the main changes on VAT rules deriving from the final text of the new provisions.
The document summarizes new VAT rules in Italy taking effect in 2015, including the expansion of the reverse charge mechanism and introduction of split payment rules for supplies to public bodies. It also outlines changes to VAT refund procedures reducing the need for guarantees, simplifications for usual exporters and VAT warehousing rules. The upcoming introduction of a VAT group regime in 2016 and plans to promote e-invoicing are also mentioned.
The Standard Audit File for Tax is a complex collection of electronic data that entrepreneurs will be obliged to send to the tax authorities. The types of Standard Audit File for Tax (SAF-T) that have been published show not only the structure and expected content of the files, but also their format. The regulations introduced by the Act of 10th September 2015 on amending the Tax Ordinance Act (Dz.U.z 2015r. poz.1649) oblige tax-payers to submit their tax books and accounting documents in the form of Standard Audit File for Tax (SAF-Ts).
The document summarizes changes to VAT provisions in Romania's new 2016 Tax Code. Key changes include a reduction in the standard VAT rate from 24% to 20%, an expanded scope of reverse taxation to certain supplies of immovable property and electronics, and clarification of rules around abuse of rights and the right to deduct VAT. The new provisions also make technical changes to aspects like VAT adjustments, capital assets, and small business exemptions.
Slovakia's corporate tax system levies a 22% tax rate on resident companies worldwide income and nonresident companies' Slovak-source income. Tax losses can be carried forward for four years. Personal income tax applies progressive rates up to 25% to residents worldwide and nonresidents' Slovak income. Value-added tax of 20% applies to goods and services, with reduced rates possible.
This document provides an overview of Poland's transfer pricing regulations. It outlines the applicable legislation, transactions subject to documentation, scope of documentation requirements, thresholds, methods, deadlines, country-by-country reporting, advance pricing agreements, and penalties. Key points include a three-tier documentation structure, documentation thresholds based on revenue, acceptable transfer pricing methods in line with OECD guidelines, extended deadlines for 2017-2018 documentation, and penalties for noncompliance.
The summary is:
The Indonesian government has launched a Voluntary Tax Disclosure Program (PPS) from January to June 2022 to allow taxpayers to disclose previously unreported tax obligations. The PPS has two conditions - condition 1 is for those who participated in the 2016 tax amnesty but did not report all assets, while condition 2 is for individual taxpayers with unreported assets from 2016-2020. The PPS allows disclosure of assets in exchange for payment of final income tax rates ranging from 6-18% depending on the type of assets and conditions. The government has also increased individual income tax rates and VAT this year as part of tax reforms.
This document summarizes tax considerations related to mergers and acquisitions (M&A) in France. It discusses recent tax law developments in France, including reductions to the corporate tax rate. It also provides an overview of key tax implications of share acquisitions in France, such as treatment of tax attributes after an acquisition and the availability of tax consolidation groups. The document notes that qualifying share acquisitions and reorganizations can be completed on a tax-deferred basis in France.
Similar to Changes in Polish corporate income tax 2020 (20)
Podsumowanie konferencji FRN na temat DPSN 2021 z 16.06.2021PwC Polska
Zapraszamy do pobrania notatek wizualnych podsumowujących konferencję Forum Rad Nadzorczych pt. "DPSN 2021. Zarządzaj. Nadzoruj. Komunikuj. Jak zbudować nowoczesny i zrównoważony ład korporacyjny?".
Automatyzacja raportowania-podatkowego-finansowegoPwC Polska
Zapraszamy do obejrzenia prezentacji z webinarium, podczas którego eksperci PwC przybliżyli kwestie raportowania podatkowo-finansowego oraz zaprezentowali przykładowe rozwiązania.
Więcej informacji na temat prezentowanych narzędzi:
Raportowanie NBP - Alteryx https://pwc.to/3uwfVJs
Automatyzacja procesu CIT - Taxolite https://pwc.to/3o28Z4x
Procesy finansowe – SmartCube https://pwc.to/3bhO7Rv i Lease Manager ttps://pwc.to/3f1F5cs
Sprawozdania finansowe – XML https://pwc.to/3w09ejj oraz XBRL https://pwc.to/3ewgddI
Analiza rynku ecommerce w Polsce 2021-2026PwC Polska
Z analizy przeprowadzonej przez PwC wynika, że w 2026 r. wartość brutto polskiego rynku handlu e-commerce będzie na poziomie 162 mld zł. Oznacza to średnioroczny wzrost o 12%. Najszybciej będzie rosła sprzedaż produktów spożywczych oraz z kategorii zdrowie i uroda. Już w 2020 r. kanał online miał 14% udziału w wartości sprzedaży detalicznej w Polsce, na co wpływ miała m.in. pandemia i przyspieszony rozwój platform e-commerce.
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BriansClub.cm, a famous platform on the dark web, has become one of the most infamous carding marketplaces, specializing in the sale of stolen credit card data.
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1. Changes in Polish
corporate income tax
2020
Presentation by Marcin Jaworski and Michał Jagielski
September 2019
2. PwC
1. Bad debts - increase/decrease of the taxable base
2. Withholding Tax and Notional Interest Deduction (full entry into
force)
3. Implementation of the Anti-Tax Avoidance Directive (ATAD 2)
4. Planned changes in Advance Pricing Agreements (APAs)
5. Cooperation agreements with tax authorities
6. VAT whitelist vs tax deductible costs
Agenda
23 September 2019Changes in Polish corporate income tax 2020
2
3. PwC
Which of the tax
provisions introduced in
recent years would you
consider to have
the greatest impact on
your business:
(a) art. 15e - intangible
services cost limitation
(b) changes in withholding
tax
(c) changes in transfer
pricing rules
5. PwC
by the value of due
receivables, if
monetary payment
has not been paid or
sold
Taxpayer may reduce /
must increase the tax
base, if the liability has
not been settled / sold by
the date of tax return
submission
If the liability is settled in
the following tax period,
the taxpayers are obliged
to increase / reduce
the tax base in the
subsequent period.
Bad debts - increase/decrease of the taxable base
23 September 2019Changes in Polish corporate income tax 2020
5
Monetary payment - remuneration for the supply
of goods or services in a commercial transaction
the tax base:
may be
reduced
by the value of
unsettled monetary
payment, which was
recognized as tax
deductible cost
is increased
after 90 days from the invoice due date as specified in
the invoice / contract, the taxpayer may / should reduce
/ increase the tax base
The reduction / increase should be shown in the tax
return submitted for the tax year as well as monthly
advances.
7. PwC
Withholding tax in Poland – a new mechanism
A completely new mechanism of settlement of WHT in relation to payments exceeding PLN 2 million
per annum for each taxpayer is to be introduced.
Payments not
exceeding PLN 2
million per
annum –
additional
documentation
• Tax remitter is entitled to apply reduced WHT rate or
WHT exemption in accordance with previous WHT
provisions.
• Additional conditio of due care
Payments
exceeding PLN 2
million per
annum –
certification
proces
• The tax remitter is obliged to withhold domestic WHT
subject to two exemptions (certification process and
opinion).
7
New definition of beneficial owner.
23 September 2019Changes in Polish corporate income tax 2020
8. PwC
Withholding tax in Poland – payment > 2MLN
Formal opinion (for Directive based exemptions only)
• Taxpayer or tax remitter which incurred the economic cost of WHT should be able to apply to the tax authorities for an
opinion confirming that tax may not be withheld based on the Parent-Subsidiary Directive or Interest/Royalties Directive
implemented to the CIT Law.
• The opinion shall be issued within 6 months from date of application and be valid for 36 months. Application for the
opinion shall be subject to fee of PLN 2,000.
• Tax application for the opinion might be rejected if:
o the taxpayer does not meet the requirements stipulated in the CIT Law;
o anti-avoidance provisions may be applicable;
o documents attached to the application are not in accordance with the factual circumstances;
o the taxpayer does not conduct a business activity in the country of his tax residence.
Certification process
• New mechanism will allow tax remitters not to withhold tax in relation to payments exceeding PLN 2 million per annum, if
the remitter submits a statement confirming that:
1. it possesses all documents required by tax regulations necessary for applying reduced WHT rate or exemption from
WHT;
2. it is not aware of any circumstances which speak against granting tax exemption and such verification was done with
due diligence.
• The statement should be signed by the head of the tax remitter entity under penalty liability.
8
23 September 2019Changes in Polish corporate income tax 2020
9. PwC
Withholding tax in Poland – payment > 2MLN
Statement of the remitter and their personal liability
false statement tax audit additional tax liability
10% of a tax base of the payment for
which the tax was not collected or when a
reduced rate was applied
20% if a tax base is higher than PLN
15 MLN – to the surplus of that amount.
Additionally, the authority will apply the 20%
rate when it has not been 10 years since the
decision about additional tax obligation was
delivered or if the transfer pricing
documentation has not been submitted
30% if a tax base is higher than PLN
15 MLN and it has not been 10 years since
the decision about additional tax obligation
was delivered or if the transfer pricing
documentation has not been submitted (two
conditions have to be met jointly)
=
9
23 September 2019Changes in Polish corporate income tax 2020
10. PwC
Withholding tax in Poland – payment > 2MLN
WHT refund
Entity eligible for refund
Taxpayer / remitter shall have the right to claim for a WHT refund.
Form of the claim
Refund application will need to be submitted by means of electronic communication.
At the moment, a template of application form is not yet available.
Procedure
Refund procedure should be completed within 6 months.
Before tax refund, tax authorities will verify, among others purpose of payment and so-called the
taxpayer's business substance (the existence of "empty" companies will make it impossible to refund
the tax). The authorities will refuse to return funds if the payment is related to the so-called tax planning.
In case there are doubts regarding fulfilment of conditions for a refund, a tax audit of a taxpayer may be
initiated.
10
23 September 2019Changes in Polish corporate income tax 2020
11. PwC
Withholding tax in Poland – payment > 2MLN
WHT refund (cont’d)
Taxpayer / remitter shall have the right to claim for a WHT refund. WHT refund procedure
will be similar to current WHT claims, requiring:
1. extensive analysis of source documents;
2. collection of additional documentation, including:
11
Strategic
business
planning
taxpayer’s
statement on
fulfilment of the
conditions for
exemption
statement of the
beneficial
ownership status
relevant
agreements
bank transfers
confirming
payments
subject to WHT
declaration as
to the
truthfulness of
the required
documents
certificate of tax
residence
Documents prepared
by an applicant
Documents prepared
by a taxpayer
23 September 2019Changes in Polish corporate income tax 2020
statement
confirming real
economic
activity of the
taxpayer in the
country of its
residence
12. PwC
WHT Navigator - unique PwC tool helping in
WHT procedures
WHT Navigator:
The WHT Navigator is intended as a tool that may be shared by the tax remitter with the taxpayer, to
be populated with relevant data, information and source documents.
Analysis
of business
substance
of holding
companies
Certification
of investment
funds
Tax litigation
and support
during
tax audits
Review of
significant
business
activity for
the purpose
of CFC
provision
Review of
business
justification
of cross-border
transactions
12
23 September 2019Changes in Polish corporate income tax 2020
13. PwC
Withholding tax in Poland – small GAAR
Small GAAR which used to be applicable only to dividend payments will used by the tax authorities to all WHT
payments, i.e. to interest and royalty payments.
The applicability of WHT exemption, resulting from the EU Directives, will take place provided small GAAR is not
used. Under the small GAAR, Poland shall deny the benefits of the Parent-Subsidiary Directive and Interest/
Royalties Directive, to a legal transaction or series of legal transactions which, having been put into place for the
main purpose or one of the main purposes of obtaining a tax advantage, are not genuine having regard to all
relevant facts and circumstances.
The small GAAR may apply if the structure within which the payment is made:
- was mainly aimed at achieving tax benefits;
- is not supported by a proper business reasons;
- does not reflect economic reality.
13
23 September 2019Changes in Polish corporate income tax 2020
14. PwC
National interest deduction
As of 1 January 2020 entities shall be allowed to recognize
certain amounts (calculated as interest based on the market
level)
tax deductible costs related to:
• retained profits, and
• contribution to equity.
Contribution
to equity
Retained
profits
Multiply by NBP
reference rate*
plus 1%
Cost base
Additional deduction
cannot exceed
PLN 250k per year
Deduction applicable if
equity not returned
within 3 years
14
*currently 1,5%
23 September 2019Changes in Polish corporate income tax 2020
16. PwC
ATAD I & II
Status Domestic Implementation Process - EU-28 Member
States
EU Country Measure taken/planned
Poland Most of regulations relating to ATAD’s implementation in Poland, including CFC regulations, thin capitalization rules and GAAR rules are
already in place. They may be considered as compliant with the Directives.
As of 1 January 2019 in particular the following ATAD related rules were introduced or amended in the domestic CIT regulations:
• Exit tax - both for corporate entities and individuals changing residency or moving assets abroad (unrealised gain will be taxed at 19%,
possibility to pay due exit tax in 5 years installments);
• CFC regulations were amended in a way that:
✓ CFC entity will also entail trusts and foundations,
✓ the minimum (30-day) period for which shares in the company's capital should be held, for the entity to be characterized as CFC was
deleted,
✓ the tax base will consist of the company's income less the dividends received by the taxpayer from the company and income from the
paid disposal of CFC shares by the taxpayer,
• The definition of CFC was also changed. As of 2019 provisions refer to a foreign controlled entity (instead of a foreign controlled company).
In addition, the CFC's income may be taxed with a solidarity tax of 4% (additional tax imposed on individuals).
• GAAR regulations were changed – in particular there is an additional tax liability applied in case tax authorities issue a decision within GAAR
regulations;
• GAAR also applies to domestic exemption for interest and royalties (in case such interest / royalties are paid within an artificial structure a
taxpayer will be denied a possibility to apply tax exemption from WHT in Poland).
16
23 September 2019Changes in Polish corporate income tax 2020
17. PwC
ATAD I & II
Status Domestic Implementation Process - EU-28 Member
States
EU Country Measure taken/planned
Poland Poland’s Ministry of Finance published, on 23 August 2019, a draft bill setting forth several provisions to implement certain anti-hybrid
measures.
Hybrid mismatches may occur when jurisdictions have different regulations in the tax qualification of sources of income or types of entities. It
results. It results in double deduction of payments as tax deductible costs or in deduction of costs without inclusion as taxable revenues on the
other side of the transaction.
The following hybrid mismatch arrangements are addressed by ATAD 2:
• Hybrid entity mismatches,
• Hybrid financial instrument mismatches,
• Hybrid transfers,
• Hybrid permanent establishment,
• Imported mismatches,
• Tax residency mismatches.
The draft is in legislative process. If approved, the effective date of the new provisions should be 1 January 2020.
17
23 September 2019Changes in Polish corporate income tax 2020
19. PwC
Planned changes in Advance Pricing Agreements (APAs)
23 September 2019Changes in Polish corporate income tax 2020
19
An Advance Pricing Agreement (APA) is a formal decision based on which the transfer
price of a controlled transaction is considered to have been agreed on terms that would
have been agreed on by unrelated parties
✓ According to the project, an investor intending to establish an affiliate in Poland may
also apply for APA
✓ The Head of the National Fiscal Administration verifies compliance with APA
Impact on art. 15e
Taxpayers are obliged to exclude from tax-deductible costs of certain costs incurred
directly or indirectly for related entities.
Now
The limitation does not apply for remuneration for transactions covered with APA –
applicable also to the tax year the APA decision was issued and the previous tax year
Planned changes
The limitation does not apply for remuneration for transactions covered with APA
The bill project is currently being
proceeded by Public Finances
Committee.
The procedure for issuing should be
completed not later than within:
― unilateral APA - 6 months,
― bilateral APA - 12 months,
― multilateral APA - 18 months.
21. PwC
Cooperation agreements with tax authorities
23 September 2019Changes in Polish corporate income tax 2020
21
Taxpayer may terminate the agreement
at any time
An agreement may be concluded with a
taxpayer who has received a positive
opinion from the preliminary audit
The agreement shall be concluded in
writing for an indefinite time period
Concluded on request on taxes within
the jurisdiction of the National Fiscal
Administration
The Head of the National Fiscal
Administration keeps register of the
taxpayers who entered into an
agreement
An application for a contract may be
filed by a taxpayer whose income in the
previous tax year exceeded EUR 50 m
The bill project is currently being proceeded by Public Finances Committee.
22. PwC
Cooperation agreements with tax authorities
23 September 2019
22
Taxpayer
Is obliged to:
• perform tax obligations voluntarily and properly,
• have an effective and adequate internal tax
procedures (internal tax supervision framework),
• report to the Head of the National Fiscal
Administration without request relevant tax issues
which may reasonably become a source of
dispute with tax authority, or information that may
affect the taxpayer obtaining tax benefits in line
with the materiality thresholds as set out in the
agreement.
Head of the National Fiscal Administration
within the agreement:
• adjusts frequency and form of verification the
taxpayer's performance of tax obligations to the
effectiveness and adequacy of the internal tax audit
procedures and previous cooperation with tax
authorities,
• conducts tax audit,
• approves certain tax verification activities conducted
by tax authorities.
The bill project is currently being proceeded by Public Finances Committee.
23. PwC
Does your group
participate in cooperative
compliance programs in
other jurisdictions?
Will it be willing to enter
into cooperation
agreement in Poland?
(a) Yes – the group
participates in cooperative
compliance and potentially
will be willing to enter into
cooperation agreement in
Poland
(b) Maybe - the group does
not participate in
cooperative compliance,
but plans to
(c) No – the group does not
participate in cooperative
compliance and is not
willing to participate
25. PwC
23 September 2019Changes in Polish corporate income tax 2020
25
The white list
The Head of the National Revenue
Administration maintains the list
containing data on entities registered
as the VAT taxpayers (the so-called
“whitelist”). The white list includes
information e.g. on taxpayers bank
accounts numbers.
VAT whitelist vs tax deductible costs
Tax deductibility limitation
Expenses paid via transfer to bank
account which is not included in the
list, cannot be treated as tax
deductible cost. Obligation to settle
your expenses with use of bank
accounts mentioned in the white list
is applicable to transactions
exceeding value of PLN 15 000.
Notification procedure
Above sanctions will not apply if the
taxpayer notifies the head of the
tax office about the payment made
to an account other than the one
included in the list - within three
days from the date of the payment
being ordered.
Enters into force 1 January 2020