28 June 2022 The Ministry of Finance referred to the arrangements and public consultation of the draft law amending the Corporate Income Tax Act and certain other laws (UD404), with a deadline 14 days to comment.
The project provides, among others, for the following solutions:
- modification and postponement of entry into force of minimum income tax provisions
- repeal of the so-called "hidden dividend" provisions
- changes in the rules on foreign controlled entities (CFCs)
Amendment of the rules on taxation of transferred income
waiving some of the payers' obligations to tax at source interest and discount on fiscal securities and making the statement of the payer more flexible, excluding the obligation to use the payment & refund mechanism
changes in the settlement of debt financing costs in tax costs
amendments to the rules on relief first Public offer
simplification of the so-called "bad debt relief" rules
amending the provisions concerning the Polish holding company (PSH)
Amendment to the rules on flat-rate taxation on company income
amendment of provisions on the documentation obligation for so-called Paradise transactions
clarification of the obligation to communicate to the taxable person the information on non-resident contracts to the head of the tax office in the event of a transfer pricing obligation
amending the provisions of the Health Care Benefits Act by regulating the situation where the insured entrepreneur (a flat-rate worker) does not provide the Social Insurance Institution with information on the monthly income from business activity
Clarification of provisions on loss accounting by companies forming tax groups
The draft, together with justification and impact assessment, is available in the Public Information Bulletin on the Government Legislative Centre website, on the Government Legislative Process website: https://legislacja.gov.pl/projekt/12361255