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Polish Deal – changes in transfer pricing


Taxpayers have already become accustomed to frequent changes in regulations concerning transfer pricing regulations. The latest proposal of the Ministry of Finance in this area are included in the bill of July 26, 2021, which implements the government's "Polish Deal" program.

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New regulations do not provide for a penalty for incorrect completion of the “MPP” (“SP”) field in JPK_V7M and JPK_V7K files


As of 1 July this year, an amendment to the regulation of June 9, 2021 on the detailed scope of data contained in tax declarations and records with regard to the tax on goods and services came into force. The implemented changes brought new questions and doubts to taxpayers, the answers to which they will have to find as soon as possible, because by 25 August they are obliged to submit JPK (SAF-T) returns for July taking already into account the new regulations.

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ICS with a break for enrichment. Destruction of part of goods does not preclude tax advantages


Intra-community supply of goods is in principle taxable at a 0% VAT rate. What, however, if certain additional works are performed on the goods in the meantime? The legislator has provided for this possibility. If certain conditions set out in implementing regulations are met, the sellers retain the right to apply the preferential rates. Nevertheless, each supply is different and may give rise to new doubts.

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Sale and lease back in the Zone. Does it pay off?


The Polish Investment Zone offers great opportunities, but it also poses many questions. Ascertaining properly the level of expenses and the moment they are incurred may prove a considerable challenge. Any mistakes made in such matters may prove very costly. This is because the decisions granting support make the public aid conditional on a proper settlement of the costs of a new investment. No wonder then that an increasing number of companies are opting for an additional protection in the form of a private tax ruling.

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Launching a production line. Supply of goods or provision of services?


Implementing a major investment project, such as the preparation and launch of a production line, is not only an organisational and logistics challenge. The investors and contractors must also face the requirement of proper qualification of the undertaking for tax purposes.

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Voluntary redemption of shares for cancellation without consideration. Does revenue arise?

On March 11, 2021 the Head of the National Revenue Information Service (hereinafter called: ‘the KIS Head’) issued an individual ruling ref. no. 0111-KDIB2-1.4010.465.2020.2.AP concerning CIT settlements in connection with redemption of own shares for the purpose of their voluntary cancellation without consideration.
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