Use of investment fund for planned investments
An investment fund – in addition to its standard function of investing the money collected – can act as a “holding company” for carrying out specific investments.
Conclusions from the review of the safeguard opinions issued to date
Protective opinions issued by the Head of the National Tax Administration (KAS) are an important tool for providing legal certainty to taxpayers. Faced with potential tax proceedings, taxpayers can apply for such opinions, which protect them from the risk that their actions will be considered an attempt to circumvent tax law. In our latest blog post, we will take a look at some of the significant decisions of the Head of KAS in recent months regarding issues such as restructurings, reduction of depreciation rates, simplification of ownership structure or cross-border mergers. We will analyze both the content of these decisions and their economic context to show how these opinions affect everyday business practices and tax management.
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.
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.
PSH – What is a Polish Holding Company?
The introduction of new regulations always raises many questions and uncertainties. Above all, we want to know what these changes mean for us and how they might affect our operations. As we begin 2022, Poland has introduced significant changes for investors and companies interested in holding structures. The new concept of the Polish Holding Company (PSH) is a proposal for favorable tax conditions aimed at attracting and retaining capital in our country. Therefore, in the post we will take a closer look at this solution, find out what a Polish Holding Company is, what conditions it must meet and what we need to know about its subsidiaries.
PSH – Tax benefits for a Polish holding company
These days, more and more entrepreneurs are thinking about optimizing their tax structure. Properly organized holding structures can bring significant benefits, including significant tax benefits. The Income Tax Law provides a number of preferences for such entities, including tax exemption of income from the paid disposal of shares (stocks) and tax exemption of dividend income.
PSI – Tax exemption for entrepreneurs on the basis of support decisions – calculation rules
Taking advantage of the Polish Investment Zone’s preferences requires investors to make a detailed calculation of exempt income and tax credits. These are key steps to effectively take advantage of the available benefits. In our latest blog post, we explain how these calculations should be performed. We discuss issues such as cost imputation, proportional cost imputation in the absence of direct imputation, and how to calculate the public assistance limit. In addition, we explain how the loss arising from new investment affects the calculations. Understanding these principles can help investors take better advantage of the preferences of the Polish Investment Zone.
PSH – Practical aspects related to the application of tax exemptions
In the business world, strategies based on the creation of holding structures are often used to optimize taxation and manage various business units. As a result, issues related to the proper functioning of such structures and their taxation rules are becoming increasingly important. In today’s post, we will focus on the criteria that must be met for a holding company to qualify for the Polish Holding Zone (PSH) preference. We will cover topics such as actual economic activity, the specifics of listed companies and the reporting obligations of holding companies.