Creating a complex structure of entities in corporate groups has been a common practice so far, and the possibility of tax optimization is one of its key reasons. Also, many enterprises using SAP in Poland operate with carved-out commercial and/or production companies, shared service centers (Financial Shared Service Centers, HR Service Centers) and other entities with legal personality as well as handled as separate business entities in SAP systems.
In fact, in 2018 entrepreneurs face the biggest changes in CIT in recent years. Tax authorities are trying to implement the EU directive (ATAD of 2016) and to force entrepreneurs on their own to give up tax optimization.
The main source of changes is the Act of 27 October 2017 amending the Act on Personal Income Tax, the Act on Corporate Income Tax and the Act on Flat-Rate Income Tax on Certain Revenues Earned by Natural Persons (Dz. U. [Journal of Laws] of 2017, item 2175). The new provisions entered into force on January 1, 2018.
The Act introduces changes regarding i.a.:
- separate calculation of income from capital gains and other income (sources of income) and lack of possibility to offset capital losses against income ...