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Polish Deal

Changes in transfer pricing from 1 January 2022
As of January 1, 2022, "The Polish Deal" introduced a number of new regulations that significantly affect taxpayers. The Act includes many key issues that directly affect affiliated entities. What changes affect the area of…
Polish Deal - new regulations on check acquisition
Regulations introducing the Polish Deal added a new section to the Act of 16.11.2016 on the National Tax Administration, dedicated to check acquisition (Articles 94k-94x), commonly known as controlled acquisition.
Polish Deal - Introduction of VAT groups
The regulations introducing the “Polish Deal” also contain changes concerning VAT. One of the most important is the introduction of VAT groups—a solution providing for the possibility of treating a group of entities as a…
WHT from January 2022
Under the Polish Deal provisions, changes to withholding tax will enter into force in January 2022. According to the bill, the changes concern: due diligence, the definition of “beneficial owner”, the “pay and refund” mechanism,…
Taxation of business operators under the “Polish Deal”
The Act of 29 October 2021 Amending the Personal Income Tax Act, the Corporate Income Tax Act and Certain Other Acts has been published in the Journal of Laws (Dz.U. 2021 item 2105). The new…
Polish Deal - tax changes for employees
From 1 January 2022, the package of tax changes introduced under the Polish Deal will enter into force in Poland. On 16 November 2021 the act introducing the new regulations was signed by the President…
"Polish Deal": summary of the most important changes in taxes
On Tuesday, November 18, 2021, the president signed the law on tax changes, which is provided for in the so-called "Polish Deal ". Therefore, we are sure that from January 1, 2022 we will all…
Changes in the alternative minimum corporate income tax
On 14 September 2021 the Polish government made a correction to its bill to amend the income tax acts which it had filed with the Sejm on 8 September 2021 as part of the Polish…
Changes in VAT: Taxation of financial services, Promotion of non-cash payments in Poland and Changes to binding rate information
In July, the Polish government presented a bill to introduce broad changes to tax and insurance laws, known as the “Polish Deal.” In addition to changes in income taxes, the bill also provides for significant…
Key changes in transfer pricing: Comparative/consistency analysis, Adjustment of transfer prices, Financial safe harbour, Exemption from the obligation to prepare transfer pricing documentation, part 2
In the second part of our series of articles we describe the most important changes proposed under the project called "Polish Deal" connected with the topic of transfer pricing. These changes pertain to a number…
CIT on pass-through income
Amendments to the Corporate Income Tax Act introduced by the Polish Deal also include additional, previously non-existent fiscal burdens, which are intended to further tighten the existing tax system in Poland. The tax on pass-through…
Adjustment of transfer prices: Current law and changes proposed in the Polish Deal
Adjustment of transfer prices is a mechanism applied in settlements between related entities. The appropriate classification of a settlement as a transfer pricing adjustment (as referred to in Art. 11e of the Corporate Income Tax…
Key changes in transfer pricing: Tax and investment agreements, ORD-U, Sanctions in the Fiscal Penal Code part 3
In the third part of our series of articles we describe last changes proposed under the project called "Polish Deal" connected with the topic of transfer pricing. These changes pertain to a number of acts,…
Key changes in transfer pricing: Value of transactions, Deadlines, Statement, Form TPR-C/TPR-P, part 1
Below we describe the most important changes proposed under the project called "Polish Deal" connected with the topic of transfer pricing. These changes pertain to a number of acts, i.e. the PIT Act, the CIT…
Changes in costs of debt financing
The changes to the Corporate Income Tax Act introduced by the Polish Deal also affect the limits on including costs of debt financing among deductible revenue-earning costs (CIT Act Art. 15c).
Changes in VAT in so-called VAT groups
In July, the Polish government presented a bill to introduce broad changes to tax and insurance laws, known as the “Polish Deal.” In addition to changes in income taxes, the bill also provides for significant…
Limitation of depreciation costs in real estate companies
Amendments to the Corporate Income Tax Act proposed by the Polish Deal introduce an unfavourable regulation regarding the possibility to treat as tax deductible costs depreciation write-offs on real estate in real estate companies.
Key changes in transfer pricing
Below we present the most important changes proposed under the project called "Polish Deal" connected with the topic of transfer pricing.
Alternative minimum corporate income tax and changes regarding limiting costs of intangible services provided by related parties
On 8 September 2021, an updated draft of amendments to tax laws to the Polish Deal programme was published. The most important of them - which comes as somewhat of a surprise - concerns a…
Tax abolition – introduction of a temporary income tax solution for taxpayers
Draft law introducing changes in taxation related to the Polish Deal also contains one institution of tax abolition (voluntary disclosure), which has been rarely encountered in the Polish legal system. By the authors of these…
Changes in withholding tax
The remitter may apply a reduced WHT rate or not collect the tax at all, if allowed by a tax treaty or by specific regulations. Then the remitter is required to hold a certificate of…
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