Tax Poland Commentary 1-2017

Major increase in the tax burden, but also greater scope for lawfully managing the taxable result in the latest legislative proposals for amendment of CIT and PIT laws


In recent days a legislative proposal has been published which would amend laws on tax treatment of income (bill of 6 July 2017). According to the statement of reasons for the proposal, the aim is to further tighten up the tax system and (partially) implement the ATAD.

The proposal would increase the taxable base declared by many taxpayers and lead to a more complex tax assessment and payment process. To a lesser extent, the proposal also contains some regulations that would be favourable to taxpayers. 
The most important changes proposed in the bill are as follows:
  1. Minimum tax on commercial real estate
  2. Separate treatment of sources of income
  3. Limit on expenditure on intangible services, as well as remuneration and the employee benefit fund
  4. More undercapitalisation restrictions
  5. Amendments to CFC regulations
  6. Easing of conditions for tax capital groups
  7. Higher value of fixed assets which can be classed as tax deductible once


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