Uchman and Partners

June 27, 2022

Charter of Fundamental Rights - protection of the taxpayer's rights and victory in a dispute with the tax authority.

How the provisions of the Charter of Fundamental Rights, if used correctly, can help in the fight to protect taxpayers' rights.

June 27, 2022

Acquisition of options for shares of a foreign entity by a Polish resident

Polish residents cooperating with foreign contractors often receive an offer to participate in an incentive program, which provides for the free acquisition of stock options, and then transforming them into shares. The question arises whether the mere acquisition of an option generates taxable income in Poland? In the opinion of our Law Firm, this event, provided that certain conditions are met, does not allow for the recognition that it will be necessary to recognize tax revenue.

June 20, 2022

Protection of the taxpayer's rights - a complaint against the decision to leave the application for a tax interpretation without consideration

How the provisions of the Charter of Fundamental Rights, if used correctly, can help in the fight to protect taxpayers' rights.

June 13, 2022

Tax Capital Group (PGK).
The risk of losing its status.

Operating within the TCG is also associated with the risk that results from the need to comply with very strict conditions. The loss of the PGK status may turn out to be very severe.

June 13, 2022

Tax Capital Group (PGK).
Terms of establishment and benefits.

How did the legislator make it possible to use this legal and tax tool to reduce tax liabilities within the capital group? What is the impact of TCG on the freedom to make transactions between its related entities?

June 6, 2022

One-sided correction

The purpose of the unilateral adjustment is to eliminate double taxation of related parties' income if the income of the domestic related party is included in the income of the foreign related party and (...)

30 houses in 2022

Mutual Agreement Procedure - MAP

Elimination of double taxation in the case of related entities takes place only as a result of the implementation of the resolution adopted under the mutual communication procedure (MAP)

September 23, 2021

SLIM VAT 2 - simplification or complication of regulations?

The amendment to the VAT Act introduces further changes to the regulations called the SLIM VAT 2 package. Most of them will enter into force on October 1, 2021, and several of them will apply from September 7, 2021. Is the next amendment to the VAT Act a simplification or an even greater complication of the regulations?

September 16, 2021

CIT changes proposed by the European Commission

The European Commission proposes to unify the tax system for legal persons operating in the European Union. The communication lists the main assumptions of the planned CIT reform.

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