Poland: Parliament approves a bill to amend various income tax rules
On 30 September 2020, the Polish lower house of Parliament (Sejm) approved a Bill No.642 amending various income tax rules for business. The measures of Bill No. 642 will apply from 1 January 2021. The bill includes a number of proposed tax
See MorePoland: Council Ministers publishes draft bill amending CIT rules
On 16 September 2020, the Polish Council of Ministers published a draft bill amending the corporate income tax (CIT) rules to be in force from 1 January 2021. The bill includes the following tax measures; Limited partnerships in Poland are
See MorePoland clarifies the treatment of dividends under TP rules
On 6 August 2020, the Polish Ministry of Finance has issued a guidance on whether a dividend payment among related entities falls within the scope of the definition of a “controlled transaction” for transfer pricing purposes. The uncertainty
See MoreDAC6 Updates: Optional deferral of DAC6 reporting deadlines
On 24 June 2020, the European Council reached agreement on an optional 6-month postponement to the reporting deadlines for relevant taxpayers under EU Directive 2018/822 (DAC6), and a delay to the exchange of information under
See MoreCOVID 19: Poland further postpones withholding tax rules to 31 December 2020
On 24 June 2020, the Polish Ministry of Finance released a decree that further postponed the effective date of withholding tax rules for corporate income tax purposes. The new effective date is 31 December 2020. The withholding tax was originally
See MorePoland defers the Mandatory Disclosure Rules (DAC 6) reporting deadlines
On 30 June 2020, the Polish Ministry of Finance has published a regulation that provides for the deferral of reporting on cross-border arrangements (DAC6) provided by Council Directive (EU) 2020/876. The deferred deadlines for “re-submission”
See MorePoland: Ministry of Finance further extends TP documentation deadline due to COVID 19
On 24 June 2020, the Polish Ministry of Finance announced the further extension of transfer pricing documentation deadlines due to the coronavirus pandemic. The announcement extends the local transfer pricing documentation preparation deadline as
See MorePoland: Parliament passes a law implementing ATADII & DAC 6
On 18 June 2020, the higher chamber of the parliament passed a bill implementing the rules related to hybrid mismatches with third countries (ATAD II) and completing the transposition of the DAC 6 rules in its domestic legislation. Under the
See MoreCOVID-19: Poland extends the deadline for local transfer pricing documentation
On 17 April 2020, the President signed the law on special aid instruments in connection with the spread of the SARS-CoV-2 virus, or the so-called Anti-Crisis Shield 2.0. Under the law, the deadline for submitting local transfer pricing
See MoreCOVID-19: Poland extends income tax filing deadline until 31 May 2020
On 25 March 2020, the Ministry of Finance announced that the deadlines for submitting CIT-8 returns by corporate taxpayers and paying the corporate tax due for 2019 for all taxpayers are extended until 31 May 2020. For taxpayers that have only
See MorePoland: Council of Ministers submit ATAD2 hybrid mismatch measures to parliament
On 5 February 2020, Poland's Council of Ministers submitted some tax measures in parliament including the hybrid mismatch measures of the EU Anti-Tax Avoidance Directive as amended (ATAD2). ATAD2 would address tax avoidance through hybrid
See MorePoland: Administrative Court allows expenditure on intra-group services
On 6 February 2020, Polish Administrative Court (the “Court”) issued its decision on a transfer pricing case regarding Poland vs Shared Service Center. A shared service center (SSC) in Poland both provided intra-group services to the group
See MorePoland publishes decree deferring new withholding tax requirement to 1 July 2020
On 30 December 2019, a decree was published in the Journal of Laws of the Republic of Poland, which further postponed the application of the most important change to the new withholding tax system (WHT). According to the decree, withholding
See MorePoland publishes a law implementing EU directive on dispute resolution and new provisions on APAs
On 14 November 2019, Poland published the Law of 26 October 2019 on resolution of disputes over double taxation and the execution of advance pricing agreements (the “Act”), which generally entered into force on 29 November 2019. The law
See MorePoland: Council of Ministers adopts draft budget law for 2020
On 24 September 2019, the Poland Council of Ministers adopted the draft budget law for 2020. For the first time since 1989, there will be no deficit in the budget. The 2020 Budget changes the following tax measures on personal income tax; Tax
See MorePoland: Ministry of Finance publishes a draft bill to implement EU ATAD 2 anti-hybrid measures
On 23 August 2019, the Poland Ministry of Finance released a draft bill outlining several provisions to implement EU ATAD 2 anti-hybrid measures. The main purpose of implementing the anti-hybrid measures is to counteract the situation of double
See MorePoland publishes explanatory note addressing transfer pricing comparability analyses
On 19 June 2019, Poland Ministry of Finance published an explanatory note addressing transfer pricing comparability analyses. Accordingly, database for comparables could be selected locally, regionally, or even globally by considering
See MorePoland publishes law amending CbC reporting rules
On 15 April 2019, Poland published the Act of 4 April 2019 amending the Act on the exchange of tax information with other countries and certain other acts including Country-by-Country (CbC) reporting rules. Under this, if a group prepares its
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