The thin capitalization rules changes in Poland and this rule enacted as an amendment to Poland’s corporate income tax law, and signed by the president on 17 September 2014 and from 1 January 2015 the “thin capitalization” rules has been extended to include indirect holdings, and the 25% holding rule will be based on voting rights. These rule changes also cover lender and borrower companies which have common direct or indirect shareholders meeting the 25% limit. According to the new rules the new debt-to-equity ratio will be 1:1.
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ECJ decision on Germany’s deferred tax on capital gains
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