RSM Poland


Blog: Piotr WYRWA

10 June 2019

There are less than three months left until the obligatory split payment mechanism is introduced. Given how this mechanism is going to impact taxpayers’ cash flows and how many entities will have to face it on a daily basis, we may refer to this as a small revolution.

5 April 2019

It is not easy to clearly determine whether WHT shall apply to dark fiber lease or not, as it requires a detailed analysis of both a given ROU agreement concluded by the Polish entity and the provisions of a relevant DTT. This analysis proves difficult as there is no wide common practice of the Polish tax authorities in this respect, and the authorities have seemed to be overlooking the issue in question.

9 November 2018

Since a tax relief on research and development activity was introduced in 2016, relevant regulations have been amended on a yearly basis. We may have fond memories of the original regulation, as its legislator managed to use only 467 words. Currently, the R&D tax relief is provided for in more than 2,200 words in the CIT Act itself and in provisions of non-tax acts, which are going to be addressed here later.

9 June 2017

Today, I would like you to become acquainted with the judgement of the CJEU and I would like to answer the question on how to apply the tax avoidance clause in case of a merger and division of companies and the exchange of shares.

1 June 2017

The last blog entry concerning research and development relief (hereinafter: R&D relief) we ended with the conclusion that despite the liberal approach of the tax authorities, which allow the relief to be used by a large group of taxpayers, the effective implementation of the relief requires an in-depth analysis of the regulations that govern it – especially in the context of the specific nature of a given taxpayer's business activity.

27 April 2017

At the beginning of 2016, the so-called "research and development relief" (hereinafter: R&D relief) was introduced to the Personal Income Tax Act and the Corporate Income Tax Act. The mechanism of the relief lies in the possibility to deduct from taxable income expense specified in the Act (so-called "eligible costs") incurred by the taxpayer for research and development, despite the fact that the expense has already been recognized as tax deductible.

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