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Tax on shifted income


Does your company have to pay tax on shifted income?

The Polish Deal introduces a new tax in the CIT area. This means an additional burden for many companies.


If a company purchases:
  • intangible services;
  • licenses, copyrights;
  • know-how

from foreign or Polish associated enterprises;

or incurs the costs of:

  • fees for the transfer of the risk of debtor's insolvency;
  • financing;
  • charges and fees for the transfer of functions, assets or risks;

you must check whether you are subject to tax on shifted income.



What if you don't do it?


What steps should be taken to correctly settle the tax?




Tax on shifted income may also apply to domestic settlements or with another EU country. This is the case when the services are purchased or costs are incurred with respect to entities that do not carry out substantial genuine business activity. There is a risk that the concept of “substantial genuine business activity” may be interpreted to the disadvantage of settlements with SPVs or the holding company.


Rödl & Partner’s assistance

Our experts will analyse your company's situation in terms of the obligation to pay tax on shifted income.

We will describe the conditions that must be met to avoid or reduce tax on shifted income, as well as prepare internal procedures to support the fulfilment of the obligation to correctly calculate the tax.



What’s in it for you

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