Recently, a new version of a draft bill to amend Poland’s corporate income tax law (and also to amend the individual income tax law) was submitted to the parliament. The amendment will most likely come into effect on 1 January 2018.
Main changes are given below:
- Changes to the controlled foreign company (CFC) legislation, which may broaden the scope of foreign subsidiaries that meet the CFC criteria.
- Changing the rules for depreciation of intangible assets- an increase of depreciation threshold for fixed and intangible assets from PLN 3,500 to PLN 10,000.
- Amending the tax capital groups rule;
- Introducing a clause for “anti-avoidance”;
- The Bill introduces a new limitation on recognizing the costs of so-called debt financing as tax-deductible costs;
- Introduction of two-income sources-separate tax treatment of capital gains (profits) and business activity revenues, whereby the revenue and costs are billed separately for both sources;
- Interest reduction limit of 30% of EBITDA for net interest expenses with a safe harbor threshold of PLN 3 million;
- Revising the thin capitalization rules.
