• Polski
  • CIT

    16.08.2023

    Changes in transfer pricing for 2022

    The legislator has already acclimated us to annual changes in transfer pricing regulations, especially during the Covid-19 pandemic period. Therefore, in order to properly fulfill reporting obligations, it is important to stay up-to-date and be aware of the changes that have been made in this regard for 2022. One of the most important changes is one concerning the deadlines for the preparation of the documentation itself and the related forms.

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    Prototype relief

    The prototype tax credit from January 1, 2022 is available to entities engaged in research and development activities. The purpose of this relief is to support entrepreneurs to carry out activities that create new and improve existing products, processes and services. It will be available to those taxpayers who incur expenses at the stage of testing an invention, prior to mass production and marketing. A company that decides to prepare a prototype can include the expenses incurred for its creation in deductible costs, and will also gain the ability to deduct additional expenses from the tax base.

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    R&D tax credit vs. R&D Center status

    Managing innovation and research is not only a scientific mission, but also an opportunity for significant tax benefits. In Poland, where tax law is complicated, some companies may not realize that they can take advantage of tax breaks for Research and Development (R&D). Even fewer companies are aware of the special benefits available to units with Research and Development Center (CBR) status. In this post, we cover the topic of tax preferences for R&D, and specifically the benefits for entities with CBR status.

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    Simultaneous use of R&D and IP Box relief – is it possible?

    In the light of the dynamically changing tax regulatory landscape, especially for those engaged in R&D activities, it is becoming increasingly important to understand and effectively utilize the available tax credits. In this context, the R&D Tax Credit and the IP Box Tax Credit, both aimed at taxpayers engaged in R&D activities, seem extremely attractive, especially in the context of the recent changes introduced by the “Polish Deal.” However, is it possible to use both of these reliefs at the same time? What benefits might this bring to taxpayers?

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    R&D relief vs. relief for innovative employees

    With the introduction of the “Polish Deal” on January 1, 2022, there have been significant changes to the regulations governing tax credits. The purpose of these changes is to promote innovation and support research and development (R&D) in Polish companies. Among the new regulations, the most noteworthy is the “relief for support of innovative employees.” This new mechanism is intended to support those companies which, despite employing employees to conduct R&D activities, have incurred losses in a given tax year or their income does not allow full deduction of qualified expenses.

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    Tax structuring of transactions

    Are you planning to acquire a company or invest in a new business? Every investment decision carries a variety of tax implications that can have a significant impact on the ultimate profitability of your investment. In our latest MartiniTAX blog post, we outline the key tax aspects of structuring business transactions. We analyze the differences between an “asset deal” and a “share deal,” explain the tax implications for sellers and buyers, and discuss CIT, PIT, VAT and PCC tax issues in detail.

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    PSI – Traps of applying zonal relief

    Taking advantage of the Polish Investment Zone’s preferences is an attractive option for investors seeking tax benefits, but such benefits are not without risk. Recognition of eligible costs, inability to take advantage of simplified transfer pricing documentation, and potential revocation of support decisions are just some of the issues that can expose entrepreneurs to unexpected complications. In our latest blog post, we examine these risks and the Polish Investment Zone rules to help investors better understand what these preferences may mean for their business operations.

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    PSI – Practical aspects of accounting for zone relief

    The Polish Investment Zone was introduced by the Act of May 10, 2018 on supporting new investments. This solution, unlike special economic zones, makes it possible to obtain state aid throughout the country. The state aid in question relates to exemption from payment of both PIT and CIT income tax on income generated in connection with the new investment covered by the decision on support. Importantly, the exemption cannot be used by companies forming a tax capital group established or for which the period of operation has been extended since June 30, 2018.

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