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The tax separation of the transaction at withholding tax is the subject of the judgment of the Provincial Administrative Court

WSA in its judgment of 17 June 2020. (ref. I SA/Sz 65/20) with respect to licence fees (Art. 21.1.1 UoCIT) explained that „ (...) in the case of the predominant benefit and incidental benefits (which do not constitute an intrinsic economic value and are only of an...

Amendments to the regulations on tax schemes in the Public Finance Committee

Due to the Covid-19 pandemic, the process of amending the regulations on tax schemes is prolonged. The government's bill amending the Corporate Income Tax Act, the Value Added Tax Act, the Tax Information Exchange Act with other countries and certain other laws, which...

WSA in Gorzów: MDR regulations may be subject to interpretation

Voivodship Administrative Court in Gorzów Wielkopolski 8 April 2020 in the judgment I SA/Go 61/20 WSA decided that the standards resulting from the regulations defining the obligations to report on the tax schemes are of material and legal nature. This means that, in...

Extended deadlines for MDR information provision

Pursuant to Article 31y of the Act of 31 March 2020 amending the Act on special arrangements related to the prevention, prevention and combating of COVID-19, other infectious diseases and crisis situations caused by them and certain other acts (Journal of Laws of...

Tax consultation – clarification of information TPR-C and TPR-P

The Ministry of Finance has launched a tax consultation on the draft document "Questions and answers on information TPR-C and TPR-P for 2019". The tax consultation will run until 22 May 2020. Proposals for opinions, requests and comments on the draft, together with a...

Publication of TPR interactive forms

Interactive forms were published on the Tax Portal: transfer pricing information for legal entities - TPR-C (2) transfer pricing information for natural persons - TPR-P (2) These forms are used to submit transfer pricing information for the tax year starting after 31...

PGK members obliged to submit information on transfer prices TPR-C – answer of the Minister of Finance to parliamentary inquiry No 507

On 10 April 2020 the Minister of Finance replied to Parliamentary Question No 507 on the obligation to submit transfer pricing information. According to the reply submitted, companies forming a tax capital group are obliged to submit information on transfer prices to...

Changes in the scope of the certificate of residence planned in the bill on the so-called anti-crisis shield 4.0.

One of the conditions in the case of cross-border payments, taking advantage of preferential taxation by Polish entities or the possibility of not collecting the tax is proving the tax residency of the receivable recipient with a certificate of residency. In the era...

The Ministry of Finance has issued explanations concerning reporting of tax schemes

As announced, by the end of January, the Ministry of Finance issued explanations concerning reporting of tax schemes. The tax explanations published yesterday evening (hereinafter: explanations) concern the application of the provisions related to the obligation to...

Act amending the Act on Personal Income Tax, the Act on Corporate Income Tax and certain other acts adopted without amendments

23 October 2018 The Sejm adopted a law amending the Personal Income Tax Act, the Corporate Income Tax Act and some other acts. The adopted amendments provide for simplification of tax regulations, tightening of the tax system (in particular with regard to income...

Transfer pricing. 259 explanations and interpretations.

Authors:  Paula Arciszewska, Aleksandra Chojnacka, Tomasz Hopej, Sylwia Imiela, Kamil Jaśkiewicz,Justyna Kołodziejczyk, Jarosław Mika (redaktor naukowy), Karolina Ostapiuk, Beata Rawa, Paweł Rosiński, Piotr Rzepka, Maciej Samuła Year of publication: 2018 Number of...

Four draft regulations

On September 6, 2018, on the website of the Government Legislation Center, draft regulations concerning four transfer pricing materials were published: Draft from July 9, 2018. Regulation of the Minister of Finance on the detailed scope of data provided in information...

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