CRIDO TAXAND FLASH OCTOBER 2013
|
|
- Christian Lambert
- 6 years ago
- Views:
Transcription
1 ISSUES OF THE MONTH CRIDO TAXAND FLASH OCTOBER 2013 Amendments to the VAT Act Limited partnership will not be CIT taxpayer Exit fee paid to related entity constitutes tax deductible cost Contractual penalty for non-performance of an investment is not tax deductible cost A take-up of newly issued shares in SKA could constitute taxable income Income from sale of products partially manufactured in SSE could be exempted from CIT Incentive payment can be considered as indirect tax deductible cost Incentive payment is not subject to VAT Free of charge transfer of self-manufactured products was not subject to VAT Entire in-kind contribution to SKA is subject to TCLT 1
2 Amendments to the VAT Act As of 1 October 2013 Poland introduced major changes to the VAT Act. According to the most important changes: taxpayers acquiring the so-called sensitive goods (e.g. steel products, fuel) would be jointly and severally liable for the VAT payment, if: the net value of goods purchased from the given seller exceeds PLN 50k monthly, at the time of delivery, buyer knew or had reasonable grounds to presume that all or part of the amount of VAT linked with the particular supply will not be paid to the tax office, application of the reverse charge mechanism (VAT settlement by the buyer) would be extended to the transactions consisting in e.g. the supply of steel. Moreover, the government is going to maintain the current VAT rates for the years and remove the provisions on the obligatory increase of VAT rates in case of exceeding the 55% debt-to-gdp threshold. Limited partnership will not be CIT taxpayer The higher house of the Parliament (Senat) passed the bill on modification of Polish CIT and PIT Acts with minor amendments. The amendments did not concern the main idea of taxation of joint stock partnership (SKA) by CIT. Hence, it is highly probable that under the new law joint stock partnership (SKA) will become CIT taxpayer as of 1 January Moreover limited partnership (SK) will remain tax transparent. The lower house of the Parliament (Sejm) will work on the amendments proposed by Senat probably on the next session planned for 6-8 November. After that the bill will be passed to the President for his signature. This means that publishing the modification of the CIT law in the beginning of November is unlikely. Still, it is probable that the bill will be published within the deadline for modifying income tax law, i.e. 30 November. Exit fee paid to related entity constitutes tax deductible cost Judgment of the Provincial Administrative Court in Bydgoszcz of 19 September 2013 (I SA/Bd 444/13) Argument: Polish company took over the production activity performed by the foreign related entity. Company expected that the acquisition of these functions would increase its income. According to the Court, under such background, the exit fee paid by the Polish company to the foreign related entity is connected with company s income. In consequence, it can constitute tax deductible cost. The Court underlined, that the necessary condition to recognize the cost for CIT purposes is not the actual generation of income, but economically justifiable expectation to generate it. Implications for entrepreneurs: The judgment is favorable for taxpayers. It regards the exit fee linked with the international transfer of the production activity, in the case at hand to Poland. Based on the analyzed judgment, in a contrary case (if the functions are transferred from Poland to another country), Polish companies should be entitled to recognize received exit fees as taxable income. The matter raised in the judgment confirms the increasing awareness of Polish tax authorities in the area of TP issues linked with business restructuring. 2 CRIDO TAXAND FLASH OCTOBER 2013
3 Contractual penalty for non-performance of an investment is not tax deductible cost Judgment of Supreme Administrative Court of 11 September 2013 (II FSK 2629/11) Argument: According to the Court, contractual penalties for non-performance of a building investment are not tax deductible costs, although they are not excluded from the tax cost in the CIT Act. In the case at hand, the termination of the agreement and the penalty resulted from the delay in the performance of the investment. The Court reminded that the recognition of an expense as tax deductible cost depends on its link with generation of income or retaining / securing its source, and not the fact that the particular type of costs has not been included in the catalogue of non-taxable costs. As a consequence, if a taxpayer wanted to finalize the investment and achieve gains from this title, the received penalty could not be linked with generating income or retaining / securing its source. Thus, the Court judged that the penalty cannot be considered as tax deductible cost. Implications for entrepreneurs: Contractual penalties for non-performance of an investment cannot be considered as tax deductible costs just as penalties resulting from the defective performance or failure to perform the works in time. A take-up of newly issued shares in SKA could constitute taxable income Judgment of the Provincial Administrative Court in Warsaw of 17 September 2013 (III SA/Wa 831/13) based on a press release Argument: The case concerns the increase of SKA s share capital from the funds accumulated on premium capital resulting in the issuance of new shares. In Court s opinion, a shareholder taking up such shares should recognize the income from participation in SKA it should be classified as the income from the business activity. The Court ascertained that such take up of the new shares causes for the taxpayer the same tax implications as receiving inkind dividends. Implications for entrepreneurs: The judgment is negative for taxpayers. In a verbal justification the Court emphasized that its standpoint is not in line with the previous court judgments. Up to now, courts used to claim that taxable income of SKA shareholders arises only after the resolution adopted by SKA on dividend payment. Simultaneously, courts used to claim that such income should not arise when shareholders received new shares (e.g. the recent judgment of the PAC, I SA/Gd 702/13). Income from sale of products partially manufactured in SSE could be exempted from CIT Judgment of the Provincial Administrative Court in Bydgoszcz of 1 October 2013 (I SA/Bd 645/13) based on a press release Argument: In Court s opinion, placing the whole production process in a special economic zone (SSE) is not the necessary condition to apply the CIT exemption. The Court did not agree with tax authority s view that the sale of a product finally manufactured outside the SSE could not be subject to the CIT exemption. According to the Court, the entrepreneurs cannot lose the full right to benefit from the CIT exemption if they are able to separate income corresponding to the part of production process taking place in the SEE. At the same time, tax authorities are entitled to audit the taxpayer s method of such separation. 3 CRIDO TAXAND FLASH OCTOBER 2013
4 Implications for entrepreneurs: The judgment is favorable for the entrepreneurs conducting part of their production process in the area of the SSE. If it is businesswise to locate the production partially in and outside the SSE, and the entrepreneurs are able to make reliable split of income, they should be entitled to enjoy the SSE benefits in the part of the income corresponding to the production conducted in the area of the SSE. Incentive payment can be considered as indirect tax deductible cost Judgment of the Provincial Administrative Court in Rzeszów of 17 September 2013 (I SA/Rz 587/13) based on a press release Argument: A taxpayer incurred one-off charge for the benefit of a mother company for the purpose of the participation in the motivating fee incurred by the mother company. The fee was an incentive aimed at concluding a trade contract with a group s client. In a consequence, the taxpayer expected to derive economic benefits from the cooperation with the client. The court did not agree with the tax authority s view that such charge should be deducted in proportion to the duration of the trade contract. The Court found that the fee is not related to any service, but is linked solely with the conclusion of the trade contract. Implications for entrepreneurs: The judgment is favorable for the taxpayers. The Court considered that the motivating fee constitutes the indirect tax cost deducted one-off when incurring. Incentive payment is not subject to VAT Judgment of Provincial Administrative Court in Rzeszów of 5 September 2013 (I SA/Rz 523/13) Argument: Non-refundable incentive payment aiming at encouraging the potential client to enter into business cooperation is not subject to the VAT taxation, because it is not linked with any equivalent. The payment for the willingness to enter into a trade agreement (and future provision of VATable services) should be subject to VAT only if it is an integral part of the remuneration for particular services. The Court indicated that this will be the case if it is agreed that the incentive payment is returnable when the parties do not sign the contract or the party receiving the payment fails to perform its contractual obligations. Implications for entrepreneurs: The standpoint taken by the court deserves an approval. It clearly confirms that the key element of the supply of services under the VAT regulations is their equivalence and mutuality. Consequently, the non-refundable incentive payments provided to potential contractors prior to beginning of the cooperation may be tax efficient instrument of the companies marketing and business policies. Free of charge transfer of self-manufactured products was not subject to VAT Judgment of Provincial Administrative Court in Olsztyn of 12 September 2013 (I SA/Ol 370/13) Argument: The Company has provided its contractors with self-manufactured products for promotional purposes. According to the Court, from 1 April 2011 to 31 March 2013 the free-of-charge transfer of products manufactured internally was out of scope of VAT. During the above period, only free-of-charge supply of goods that were previously acquired by the taxpayer was subject to VAT. 4 CRIDO TAXAND FLASH OCTOBER 2013
5 Implications for entrepreneurs: Discussed judgment is favorable for the taxpayers. Firstly, the Court indicated that the interpretation of VAT provisions should not be broaden the production of goods cannot be treated the same as their acquisition. Secondly, the Court indicated that the favorable regulations may be applied not only with respect to gifts of small value. In our opinion, the commented judgment gives reasonable grounds to apply for the refund of the VAT overpayment by the taxpayers who, during the abovementioned 2-year period, used their own products for advertising purposes and charged VAT on these activities. Entire in-kind contribution to SKA is subject to TCLT Judgment of Provincial Administrative Court in Poznań of 15 October 2013 (III SA/Po 671/13) based on a press release Argument: The Court ruled that in case of in-kind contribution in a form of an enterprise or its organized part to the SKA, the tax base for the Tax on Civil Law Transactions (TCLT) is the entire value of the contribution enlarging the assets of the partnership. It is irrelevant that the contribution is partially allocated to the premium capital. The Court did not accept the taxpayer s standpoint that the tax base should correspond solely to the part of contribution allocated to the share capital. Implications for entrepreneurs: The Court upheld the dominant unfavorable line interpretation presented by the administrative courts regarding TCLT taxation of the contributions to SKA. In case of SKA, contrary to the capital companies, value of entire contribution is subject to TCLT. SHOULD YOU HAVE ANY ADDITIONAL QUESTIONS CONCERNING THE ABOVE ISSUES PLEASE CONTACT: Andrzej Puncewicz Partner andrzej.puncewicz@taxand.pl Paweł Toński Partner pawel.tonski@taxand.pl Crido Taxand Ul.Grzybowska 5A Warszawa crido@taxand.pl Crido Taxand Sp. z o.o. ul. Grzybowska 5a, Warszawa, crido@taxand.pl 5 CRIDO TAXAND FLASH OCTOBER 2013
CRIDO TAXAND FLASH JUNE
CRIDO TAXAND FLASH JUNE 2014 ISSUES OF THE MONTH In case of a receipt of subsidy, the related costs of tax depreciation shall be corrected in the month of receipt of the subsidy; In case of employment
More informationCRIDO TAXAND FLASH APRIL
ISSUES OF THE MONTH CRIDO TAXAND FLASH APRIL 2014 No obligation to adjust tax deductible costs if liability is settled by factor Regardless of the reason underlying the issuance of a correction invoice,
More informationCRIDO TAXAND FLASH DECEMBER Tax authorities focus on the Members of the board of limited liability companies report issued by Crido
ISSUES OF THE MONTH CRIDO TAXAND FLASH DECEMBER 2015 Tax authorities focus on the Members of the board of limited liability companies report issued by Crido Taxand and Crido Legal. TP: Polish Minister
More informationMinistry of Finance in the fight against VAT fraud. Clearing House IT System (STIR).
TOPICS OF THE MONTH Ministry of Finance in the fight against VAT fraud. Clearing House IT System (STIR). Taxation of oxygen for VAT purposes. Automatic exchange of information on tax interpretations within
More informationTRANSFER PRICING DOCUMENTATION IN POLAND
T A X TRANSFER PRICING DOCUMENTATION IN POLAND 2018 Advicero Tax Sp. z o.o. All rights reserved. TABLE OF CONTENTS INTRODUCTION... 3 KEY AMENDMENTS IN TRANSFER PRICING REGULATIONS... 3 WHEN COMPANIES /
More informationNEWSLETTER. Table of content. Topics of the month TOPICS OF THE MONTH 1 RECENT TAX RULINGS 7. August 2016
NEWSLETTER August 2016 Table of content TOPICS OF THE MONTH 1 Cash pooling agreement should be treated as loan agreement the tax consequences 2 Another judgments regarding obligation to withholding tax
More information1. What are recent tax developments in your country which are relevant for M&A deals? CFC
Poland General Poland 1. What are recent tax developments in your country which are relevant for M&A deals? CFC As of 1 January 2015, CFC regulations were implemented in Poland. Under new rules income
More informationPOLAND GLOBAL GUIDE TO M&A TAX: 2017 EDITION
POLAND 1 POLAND INTERNATIONAL DEVELOPMENTS 1. WHAT ARE RECENT TAX DEVELOPMENTS IN YOUR COUNTRY WHICH ARE RELEVANT FOR M&A DEALS AND PRIVATE EQUITY? GAAR regulations The most important changes with respect
More informationNEWSLETTER. Table of contents TOPICS OF THE MONTH 2 RECENT TAX RULINGS 5. September 2016
NEWSLETTER September 2016 Table of contents TOPICS OF THE MONTH 2 Ministry of Finance announces which costs of business trips can be deductible 2 Sale of debts as a form of tax optimization 3 Depreciation
More informationDoing business in Poland
Warsaw, 2014 Member firm of Nexia International Contents Foreword... 3 Key personnel... 6 Chapter 1 Introducing Poland... 7 Political system... 7 Legal system... 8 Language... 8 Economy... 8 Business hours...
More informationMANAGING EXCHANGE RATE DIFFERENCES FOR TAX PURPOSES
V.FINANCIAL ASPECTS OF ORGANIZATIONAL MANAGEMENT Marcin Jamroży * MANAGING EXCHANGE RATE DIFFERENCES FOR TAX PURPOSES Summary This paper aims to analyze the tax consequences of foreign exchange differences.
More informationSetting up your Business in Poland Issues to consider
Poland is situated in the heart of Central Europe and is the 9 th largest country on the continent and the 70 th in the World. Highly qualified labour force, membership in the EU, entrepreneurial spirit
More informationConsortia from a legal and business perspective the Polish approach. Jerzy Sawicki Radca prawny Senior Associate Infrastructure and Energy Practice
Consortia from a legal and business perspective the Polish approach Jerzy Sawicki Radca prawny Senior Associate Infrastructure and Energy Practice Warsaw, 13 October 2017 Presentation plan 1. What is a
More informationDOING BUSINESS IN POLAND. Why Poland?
DOING BUSINESS IN POLAND Why Poland? Poland is a country in Central East Europe. The total area of Poland is over 120,000 sq mi (9th largest in Europe) with a population of over 38 million people. Poland
More informationNEWSLETTER. May Household appliances with turnkey apartment with no right for tax preference 2
NEWSLETTER May 2016 Table of content TOPICS OF THE MONTH 2 Household appliances with turnkey apartment with no right for tax preference 2 Early termination of the contract at the request of the customer
More informationSETTING UP A COMPANY IN POLAND BY NON-EU INVESTORS. How we can help you in achieving success in international investments
SETTING UP A COMPANY IN POLAND BY NON-EU INVESTORS How we can help you in achieving success in international investments The only EU Member State which avoided the financial crisis was Poland. Foreign
More informationBWHS Law Firm. Doing Business in Poland
BWHS Law Firm Doing Business in Poland Why to invest in Poland? Polish sound economy good traditions of trade relations PL - EU member for 8 years now friendly legal environment EU funds Poland - Economic
More informationFOURTH SECTION. Application no /08 by Alojzy FORMELA against Poland lodged on 3 June 2008 STATEMENT OF FACTS
FOURTH SECTION Application no. 31651/08 by Alojzy FORMELA against Poland lodged on 3 June 2008 STATEMENT OF FACTS THE FACTS The applicant, Mr Alojzy Formela, is a Polish national who was born in 1942 and
More informationDoing Business in Poland
This document describes some of the key commercial and taxation factors that are relevant on setting up a business in Poland. Prepared by Audyt i Doradztwo Pawlik, Modzelewski i Wspólnicy sp. z o.o. and
More information1 A. 2 A PLN 9,053 [4,300 x 11 x 60% x 31 9%] 3 C 4 A. 5 C PLN 34,200 [(600, ,000) x 19%] 6 D 7 C PLN 110,000 [75, ,000]
Answers Applied Skills, TX POL Taxation Poland (TX POL) Section A December 208 Answers and Marking Scheme A 2 A 9,053 [4,300 x x 60% x 3 9%] 3 C 4 A 5 C 34,200 [(600,000 420,000) x 9%] 6 D 7 C 0,000 [75,000
More informationTransfer-pricing related disputes in Poland
www.pwc.pl Transfer-pricing related disputes in Poland February 2014 Implications of recent Polish and international legislative changes, as well as practical lessons drawn from tax audits and court proceedings
More informationTaxation in Poland 2018
Madejczyk Kancelaria Prawna sp. k. adres do korespondencji: al. ks. kard. Stefana Wyszyńskiego 17 a, 97-400 Bełchatów kontakt: ( 44 ) 635 03 25 e-mail: sekretariat@madejczyk.biz www.kancelariamadejczyk.biz
More informationGeneral Terms and Conditions
General Terms and Conditions TÜV Rheinland Polska Sp. z o.o. www.tuv.com 1. Scope of application 1.1 These General Trading Conditions shall apply to all services rendered by TÜV Rheinland Polska Sp. z
More informationSELECTED LEGAL ASPECTS OF MANAGEMENT CONTRACTS
Anna Domańska Lodz University of Technology Faculty of Mechanical Engineering Institute of Machine Tools and Production Engineering Department of Management and Economic and Legal Sciences SELECTED LEGAL
More information2018 Transfer Pricing Overview Poland
2018 Transfer Pricing Overview Poland poland@accace.com www.accace.com www.accace.pl Contents Introduction 3 Applicable Legislation 4 Transactions Subject to Transfer Pricing Documentation 5 Scope of Transfer
More informationFundamentals Level Skills Module, Paper F6 (POL)
Answers Fundamentals Level Skills Module, Paper F6 (POL) Taxation (Poland) Speedy Gonzales Sp. z o.o. June 203 Answers and Marking Scheme (a) Corporate income tax 202 Income per accounts 85,000 Advance
More informationTaxation Poland (TX- POL) (F6)
June and December 2018 Taxation Poland (TX- POL) (F6) Syllabus and study guide Guide to structure of the syllabus and study guide Overall aim of the syllabus This explains briefly the overall objective
More informationPre-Merger Notification Guide. POLAND Wardynski & Partners
Pre-Merger Notification Guide POLAND Wardynski & Partners CONTACT INFORMATION Sabina Famirska and Andrzej Madała Wardynski & Partners Aleje Ujazdowskie 10 Warsaw 00-478, Poland 48.22.437.82.00 sabina.famirska@wardynski.com.pl
More informationUHY ECA TAX NEWSLETTER CORPORATE INCOME TAX An independent member of UHY International
UHY ECA TAX NEWSLETTER CORPORATE INCOME TAX 06.03.2018 An independent member of UHY International TABLE OF CONTENTS 1. Limitation in calculating to tax deductible costs 3 2. Limitation in debt financing
More informationRecent Parliamentary Budgeting Developments in Poland from a parliamentary perspective
DR ZOFIA SZPRINGER RESEARCH BUREAU OF THE CHANCELLERY OF THE SEJM Recent Parliamentary Budgeting Developments in Poland from a parliamentary perspective Polish Constitution from 1997 includes ban on increasing
More information- Observation of competitiveness rule which is to ensure the same taxation rules apply for all taxpayers in the Member States.
The Tax on Goods and Services(VAT) Introduction VAT was introduced in Poland in 1993. Since 1 May 2004 it has been harmonized with the common system of VAT binding in the Member States of the European
More informationFrontiers in tax. Polish edition. September 2017
Frontiers in tax Polish edition September 2017 In this issue: Several SEZ permits how many sets of accounts? Revenue and expenses of an entrepreneur operating in the SEZ Services performed outside the
More information2017 Transfer Pricing Overview Poland
2017 Transfer Pricing Overview Poland poland@accace.com www.accace.com www.accace.pl Contents Applicable Legislation 3 Transactions Subject to Transfer Pricing Documentation 4 Scope of Transfer Pricing
More informationKey important changes in Polish tax legislation
Key important changes in Polish tax legislation 2019 Exit tax Withholding tax No such regulations in Polish tax system in place. In general, certain payments abroad (e.g. interest, dividends, royalties,
More informationExaminer s report F6 Taxation (POL) June 2015
Examiner s report F6 Taxation (POL) June 2015 General Comments There were two sections to the examination paper and all of the questions were compulsory. Section A consisted of 15 multiple choice questions
More informationFundamentals Level Skills Module, Paper F6 (POL)
Answers Fundamentals Level Skills Module, Paper F6 (POL) Taxation (Poland) December 2015 Answers and Marking Scheme Section A 1 C 2,944 (16,000*80%*23%) The past year proportion is used during the current
More informationLEGAL INTERPRETATION OF POLISH TAX LAW BASED ON THE INSTITUTION OF REMUNERATION OF EXCESS PAYMENT SELECTED ISSUES
STUDIES IN LOGIC, GRAMMAR AND RHETORIC 33(46) 2013 DOI: 10.2478/slgr-2013-0012 Mariusz Popławski University of Bialystok LEGAL INTERPRETATION OF POLISH TAX LAW BASED ON THE INSTITUTION OF REMUNERATION
More informationRespoTeam, Terms of Service Definitions 1.1 ORDERING ENTITY 1.2 RESPONDENT 1.3 ACCOUNT 1.4 PLATFORM 1.5 PRIVACY POLICY 1.
These Terms of Service specify rules concerning the provision of services by Symetria UX Sp. z o.o. with its registered office in Poznań (60-749), ul. Wyspiańskiego 10/3, entered into the register of entrepreneurs
More informationFundamentals Level Skills Module, Paper F6 (POL)
Answers Fundamentals Level Skills Module, Paper F6 (POL) Taxation (Poland) Section A June 2015 Answers and Marking Scheme 1 D 2 B 1,600*30%*9*34 35% = 1,484 Tutorial note: As Marta has not run a registered
More information2018 TAX GUIDELINE. Poland.
2018 TAX GUIDELINE Poland poland@accace.com www.accace.com www.accace.pl Contents General information about Poland 4 Legal forms of business 5 General rules on purchasing real estate by foreigners 5 Legal
More informationUnconsolidated Financial Statements of Bank Pekao S.A. for the year ended on 31 December 2018 Warsaw, February 2019
Unconsolidated Financial Statements of Bank Pekao S.A. for the year ended on 31 December 2018 Warsaw, February 2019 This document is a free translation of the Polish original. Terminology current in Anglo-Saxon
More information1. The financial statement of profit or loss and other comprehensive income
4FUN MEDIA S.A. 1. The financial statement of profit or loss and other comprehensive income Note Continuing operations Revenues from sales 1.2 24,351,115.32 20,981,277.30 Cost of sales 3 18,705,522.95
More informationTHEMATIC COMPILATION OF RELEVANT INFORMATION SUBMITTED BY POLAND ARTICLE 8, PARAGRAPH 5 ASSET AND INTEREST DISCLOSURE SYSTEMS POLAND (NINTH SESSION)
THEMATIC COMPILATION OF RELEVANT INFORMATION SUBMITTED BY POLAND ARTICLE 8, PARAGRAPH 5 ASSET AND INTEREST DISCLOSURE SYSTEMS POLAND (NINTH SESSION) R E P U B L I C O F P O L A N D N A T I O N A L P U
More informationLegal Newsletter. D.Dobkowski sp.k. Enforcement of civil claims in the European Union. Foreign entrepreneur s branch liquidation
D.Dobkowski sp.k. September 2011 Legal Newsletter Enforcement of civil claims in the European Union Foreign entrepreneur s branch liquidation Amendment to the Public Procurement Law Changes in the law
More informationAmendments of Serbian Tax Laws adopted by the Serbian Parliament
Amendments of Serbian Tax Laws adopted by the Serbian Parliament In the session held on 14 December 2017 the Serbian Parliament adopted amendments to the VAT Law, Corporate Income Tax (CIT) Law, the Law
More informationDINO POLSKA S.A. FINANCIAL STATEMENTS FOR THE YEAR ENDED 31 DECEMBER 2017 WITH THE AUDIT REPORT OF THE INDEPENDENT AUDITOR
FINANCIAL STATEMENTS FOR THE YEAR ENDED 31 DECEMBER 2017 WITH THE AUDIT REPORT OF THE INDEPENDENT AUDITOR Krotoszyn, 16 March 2018 Unofficial translation. Only the original Polish text is binding. Introduction
More information1. What are recent tax developments in your country which are relevant for M&A deals?
Denmark General Denmark 1. What are recent tax developments in your country which are relevant for M&A deals? During the past year, the Danish Parliament adopted new legislation in a number of different
More informationFundamentals Level Skills Module, Paper F6 (POL)
Answers Fundamentals Level Skills Module, Paper F6 (POL) Taxation (Poland) Zgrzytające Wrzeciono SA June 04 Answers and Marking Scheme (a) Corporate income tax (CIT) for 03 Loss per accounts (940,000)
More informationALCOMEX SPRINGS-POL Sp. z o.o. GENERAL TERMS AND CONDITIONS OF SALE
ALCOMEX SPRINGS-POL Sp. z o.o. GENERAL TERMS AND CONDITIONS OF SALE Article 1 Sphere of application. 1.1. These terms and conditions (hereinafter referred to as the gtcs ) shall apply to entering into
More informationPoland s MoF releases 2019 tax reform summary of key changes affecting multinational groups
11 September 2018 Global Tax Alert Poland s MoF releases 2019 tax reform summary of key changes affecting multinational groups NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition
More informationDoing business in Poland. Advicero Tax Nexia
Doing business in Poland Advicero Tax Nexia Content Foreword... 3 Key personnel... 6 Chapter 1 Introducing Poland... 6 Poland in figures... 7 Political system... 7 Legal system... 8 Language... 8 Economy...
More informationMonday Development SA Consolidated Annual Report
Monday Development SA Consolidated Annual Report 2012 CONTENTS I. LETTER TO SHAREHOLDERS, INVESTORS AND PARTNERS... 3 II. SELECTED FINANCIAL DATA... 4 III. FINANCIAL STATEMENTS... 5 IV. MANAGEMENT REPORT
More informationSETTING UP BUSINESS IN POLAND
www.antea-int.com SETTING UP BUSINESS IN POLAND 1 General Aspects Poland is situated in the heart of Europe, bordering seven other countries. Its monetary unit is the Polish zloty (PLN). Expected date
More informationObjectives and advantages. u To analyse, interpret and report on financial statements and related information to different user groups.
IFRS Workshops Application of International Financial Reporting Standards Client Relations Officer Warszawa Aleksandra Trych tel. +48 505 171 636 aleksandra.trych@pl.ey.com Poznań Katarzyna Pudelska tel.
More informationCondensed Unconsolidated Interim Financial Statements of Bank Pekao S.A. for the period from 1 January 2018 to 30 June 2018 Warsaw, August 2018
Condensed Unconsolidated Interim Financial Statements of Bank Pekao S.A. for the period from 1 January 2018 to 30 June 2018 Warsaw, August 2018 This document is a free translation of the Polish original.
More informationGERMANY GLOBAL GUIDE TO M&A TAX: 2017 EDITION
GERMANY 1 GERMANY INTERNATIONAL DEVELOPMENTS 1. WHAT ARE RECENT TAX DEVELOPMENTS IN YOUR COUNTRY WHICH ARE RELEVANT FOR M&A DEALS AND PRIVATE EQUITY? Germany has recently seen some legislative developments
More informationAsseco Group. Annual Report. Annual Report
Asseco Group Annual Report Annual Report Present in over 54 countries 7,831 in sales revenues 24,053 highly committed employees 467 in net profit for Shareholders of the Parent Company 5,459 in order backlog
More informationVAT refund to Latvian companies
VAT refund to Latvian companies November 25, 2010 Marina Kuzenko Head of SRS TD Indirect Tax Methodology Division 1 Excess VAT refund procedure Regulated by: Law on Taxes and Fees; Law on Value Added Tax,
More informationTHE LUBELSKI WĘGIEL BOGDANKA GROUP
CONSOLIDATED FINANCIAL STATEMENTS for the financial year from 1 January 2016 to 31 December 2016 BOGDANKA, MARCH 2017 CONTENTS OF THE FINANCIAL STATEMENTS CONSOLIDATED STATEMENT OF FINANCIAL POSITION (BALANCE
More informationAustria Individual Taxation
Introduction Individuals are subject to national income tax. There are no local income taxes. After 1 August 2008, inheritance and gift tax is no longer levied. Social security contributions are also levied.
More information2. Constitutional principles or rules with influence on the legislative procedure regarding non-fiscal purposed tax rules
Taxation for non-fiscal purposes By Anne Gro Enger 1 1. Introduction Taxation is most of all connected to the idea of providing revenue, but is actually composed by two main purposes: taxation for fiscal
More informationTHE OBLIGATION OF PUBLISHING ISSUED TAX INTERPRETATION (TAX RULING) UNDER POLISH LAW
THE OBLIGATION OF PUBLISHING ISSUED TAX INTERPRETATION (TAX RULING) UNDER POLISH LAW by Tomasz NOWAK, Associate Professor at University Lodz, Poland. INTRODUCTION: TAX LAW AND THE CONCEPT OF OPEN GOVERNMENT
More informationBelarus: Brief review of the key amendments to the Tax Code 2019 August 2018
Belarus: Brief review of the key amendments to the Tax Code 2019 EY started its activities in Belarus in 1994 and we opened our Minsk office in 2000. Ernst & Young Legal Services LLC provides legal services
More informationUnconsolidated Financial Statements of Bank Pekao S.A. for the year ended on 31 December 2015 Warsaw, February 2016
a This document is a free translation of the Polish original. Terminology current in Anglo-Saxon countries has been used where practicable for the purposes of this translation in order to aid understanding.
More informationTHE LONG-TERM INCENTIVE PROGRAM
Resolution No. 1 of the Extraordinary General Meeting of Pfleiderer Group S.A. with its registered seat in Wrocław dated 18 October 2017 regarding the determination of the terms of the long-term incentive
More informationRobert Pasternak, Attorney at law and Partner in Charge of Deloitte Legal. Poland
Robert Pasternak, Attorney at law and Partner in Charge of Deloitte Legal Poland FDI in Poland current situation Amount of FDI (period 1990-2015): EUR 173,6 billion (an average of PLN 26 billion) per year
More informationAnnual Financial Statements of the HYDROTOR S.A Company for the year 2010 prepared in accordance with International Financial Reporting Standards
Annual Financial Statements of the HYDROTOR S.A Company for the year 2010 prepared in accordance with International Financial Reporting Standards April 2011 1 CONTENTS Financial Statement of Comprehensive
More informationTHE VAT IN THE BANK SYSTEM
THE VAT IN THE BANK SYSTEM Krzysztof Biernacki* Abstract The bank system in the European Union plays an important role as a significant sector of the economy. Implementing in the last century -VAT exemption
More informationTax & Legal Weekly Alert
Tax & Legal Weekly Alert 2-6 April 2018 In this issue: Major changes to the Tax Code Law no. 72/2018, Government Emergency Ordinance no. 18/2018, Government Emergency Ordinance no. 25/2018 amended recently
More informationPolish model of Capacity Market
Polish model of Capacity Market As of 18 January 2018, the Act of 8 December 2017 on capacity market ( Act ) has entered into force. The aims of the Act are: (c) (d) to introduce incentives for construction
More informationFINAL REPORT AUGUST Portugal
FINAL REPORT AUGUST 2002 Portugal Contents Portugal Page 1. General remarks 1 1.1 History 1 1.2 Current situation 1 2. Key features of stock option plans 1 3. Taxation 2 3.1 Time of taxation 2 3.2 Taxable
More informationALBANIA TAX CARD 2017
ALBANIA TAX CARD 2017 TAX CARD 2017 ALBANIA Table of Contents 1. Individuals 1.1 Personal Income Tax 1.1.1 Tax Rates 1.1.2 Taxable Income 1.1.3 Exempt Income 1.1.4 Deductible Expenses 1.2 Social Security
More informationBill 7020 approved by the Luxembourg Parliament: general 2017 tax measures for corporations and individuals
www.pwc.lu/tax Bill 7020 approved by the Luxembourg Parliament: general 2017 tax measures for corporations and individuals 15 December 2016 In brief On 14 December 2016, the Luxembourg Parliament approved
More informationOPEN FINANCE S.A. WARSAW, PRZYOKOPOWA 33 FINANCIAL STATEMENTS FOR THE 2015 FINANCIAL YEAR WITH AUDITOR S OPINION AND AUDIT REPORT
WARSAW, PRZYOKOPOWA 33 FINANCIAL STATEMENTS FOR THE 2015 FINANCIAL YEAR WITH AUDITOR S OPINION AND AUDIT REPORT TABLE OF CONTENTS AUDITOR S OPINION... 3 REPORT ON THE AUDIT OF THE FINANCIAL STATEMENTS
More informationTranslation of auditor s report originally issued in Polish. The Polish original should be referred to in matters of interpretation.
Translation of auditor s report originally issued in Polish. The Polish original should be referred to in matters of interpretation. INDEPENDENT AUDITOR S REPORT ON THE AUDIT OF THE ANNUAL FINANCIAL STATEMENTS
More information1. What are recent tax developments in your country which are relevant for M&A deals?
Indonesia General Indonesia 1. What are recent tax developments in your country which are relevant for M&A deals? In 2008, the Minister of Finance issued regulation regarding the use of book value for
More informationOpinion of the Monetary Policy Council. on the Draft Budget Act for the Year 2007
N a t i o n a l B a n k o f P o l a n d Monetary Policy Council Warsaw, 6 October 2006 Opinion of the Monetary Policy Council on the Draft Budget Act for the Year 2007 General comments 1. The submitted
More informationERBUD S.A. Separate Financial Statements for the 12-month period ended 31 December 2015 (PLN '000) ERBUD S.A.
ERBUD S.A. Separate Financial Statements for the year ended 31 December 2015 1 Introduction to the Financial Statements 1. Name, business address, the subject of activity and number in the Court Register
More informationTAX STRATEGIES AS A MODERN TOOL OF FINANCIAL MANAGEMENT IN COMPANIES
Piotr Ziarkowski AGH-University of Science and Technology in Krakow Faculty of Management, third-cycle student piotrziarkowski22@gmail.com TAX STRATEGIES AS A MODERN TOOL OF FINANCIAL MANAGEMENT IN COMPANIES
More informationANNUAL REPORT. (Translation of the Estonian original) Beginning of financial year: End of financial year:
ANNUAL REPORT (Translation of the Estonian original) Beginning of financial year: 01.01.2015 End of financial year: 31.12.2015 Business name: AS SmartCap Commercial Registry no.: 12071991 Legal address:
More informationLUBELSKI WĘGIEL BOGDANKA SPÓŁKA AKCYJNA
LUBELSKI WĘGIEL BOGDANKA SPÓŁKA AKCYJNA FINANCIAL STATEMENTS for the financial year from 1 January 2016 to 31 December 2016 BOGDANKA, MARCH 2017 CONTENTS OF THE FINANCIAL STATEMENTS STATEMENT OF FINANCIAL
More informationGermany Taxable income. Introduction. 1. Income Tax Taxable persons. This chapter is based on information available up to 11 March 2010.
This chapter is based on information available up to 11 March 2010. Introduction Individuals are subject to income tax, which is increased by a solidarity surcharge. Individuals carrying on a trade or
More informationGENERAL TERMS AND CONDITIONS OF SALE OF GOODS
GENERAL TERMS AND CONDITIONS OF SALE OF GOODS OF CMC POLAND SP. Z O.O. I. GENERAL PROVISIONS 1.This General Terms and Conditions of Sale of Goods (hereinafter: GTCS) shall be applied to contracts or orders
More informationANNUAL REPORT. (translation of the Estonian original) Beginning of financial year: End of financial year:
ANNUAL REPORT (translation of the Estonian original) Beginning of financial year: 01.01.2014 End of financial year: 31.12.2014 Business name: AS SmartCap Commercial Registry no.: 12071991 Legal address:
More information1. What are recent tax developments in your country which are relevant for M&A deals?
Finland General Finland 1. What are recent tax developments in your country which are relevant for M&A deals? The most relevant recent developments in Finland relate closely to the BEPS project. Interest
More informationDoing business in Poland
www.pwc.com Doing business in Poland 2017 Agenda 1 2 3 4 5 6 7 8 9 Why Poland? Poland Country profile How to open a business in Poland in 5 steps! Establishing the company Taxation: CIT, VAT, other taxes
More informationChapter 23. General Provisions. Article 169. Concept of value added tax. Chapter 24. Taxpayers. Article 170. Taxpayers
DIVISION VII. VALUE-ADDED TAX Chapter 23. General Provisions Article 169. Concept of value added tax The value added tax, hereinafter VAT, is a form of collection to the budget of a portion of the value
More informationADDITIONAL INFORMATION to the abridged financial statements SA-QSr2 / 2006
ADDITIONAL INFORMATION to the abridged financial statements SA-QSr2 / 2006 1. Accounting principles and methods, assets and liabilities valuation methods as of the balance sheet day and profit and loss
More informationTaxation Vietnam (VNM)(F6) June & December 2017
Taxation Vietnam (VNM)(F6) June & December 2017 This syllabus and study guide is designed to help with planning study and to provide detailed information on what could be assessed in any examination session.
More informationTHE BUDIMEX GROUP CONSOLIDATED FINANCIAL STATEMNETS. For the year ended 31 December 2009
THE BUDIMEX GROUP CONSOLIDATED FINANCIAL STATEMNETS For the year ended 2009 Prepared in accordance with International Financial Reporting Standards Table of contents CONSOLIDATED STATEMENT OF FINANCIAL
More informationSALES AND COMPLAINTS REGULATIONS 1 [APPLICATION]
SALES AND COMPLAINTS REGULATIONS 1 [APPLICATION] 1. These Sales and Complaints Regulations [ hereinafter referred to as Regulations ] apply to sales contracts concluded by; a. SUDER & SUDER SP. Z O.O (limited
More informationCommittee of Experts on International Cooperation in Tax Matters Fourteenth session
Distr.: General * March 2017 Original: English Committee of Experts on International Cooperation in Tax Matters Fourteenth session New York, 3-6 April 2017 Agenda item 3(a)(ii) BEPS: Proposed General Anti-avoidance
More informationMERGER NOTIFICATION AND PROCEDURES TEMPLATE POLAND. January 2011
MERGER NOTIFICATION AND PROCEDURES TEMPLATE POLAND January 2011 IMPORTANT NOTE: This template is intended to provide initial background on the jurisdiction s merger notification and review procedures.
More informationTax Newsletter. August 2013
Tax Newsletter August 2013 Table of Contents: NEW DOCUMENTS New Decree guiding the implementation of the amended Laws on CIT and VAT New Circular on Personal Income Tax ( PIT ) GUIDING DOCUMENTS Value
More informationKOMPUTRONIK S.A. POZNAŃ, UL. WOŁCZYŃSKA 37 FINANCIAL STATEMENTS FOR THE FINANCIAL YEAR ENDED 31 MARCH 2016 WITH AUDITOR S OPINION AND AUDIT REPORT
POZNAŃ, UL. WOŁCZYŃSKA 37 FINANCIAL STATEMENTS FOR THE FINANCIAL YEAR ENDED 31 MARCH 2016 WITH AUDITOR S OPINION AND AUDIT REPORT TABLE OF CONTENTS AUDITOR S OPINION... 3 REPORT ON THE AUDIT OF THE FINANCIAL
More informationREGULATIONS. on Foreign Currency Forward Transactions (Forward Rules)
REGULATIONS on Foreign Currency Forward Transactions (Forward Rules) General Provisions 1 These Rules on Foreign Currency Forward Transactions hereinafter referred to as the Forward Rules present the detailed
More informationConsolidated Financial Statements of Bank Pekao S.A. Group for the period ended on 31 December 2014
This document is a free translation of the Polish original. Terminology current in Anglo-Saxon countries has been used where practicable for the purposes of this translation in order to aid understanding.
More informationAn education in fiscal neutrality? The Court of Appeal upholds the terms of the UK s education exemption.
An education in fiscal neutrality? The Court of Appeal upholds the terms of the UK s education exemption. Finance and Business Trading Ltd v HMRC [2016] EWCA Civ 7 George Peretz QC, Monckton Chambers The
More informationMostostal Warszawa Capital Group Consolidated financial statements prepared in accordance with the IFRS for the period 01.01.2013 31.12.2013 ADDITIONAL INFORMATION AND EXPLANATIONS 1. General information
More informationThe Conceptual Framework for Financial Reporting
1. Introduction The Conceptual Framework sets out the concepts which underlie the preparation and presentation of financial statements for external users (Conceptual Framework, Section Purpose and status
More information