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Poland: Potential benefits under “cooperation program” for large taxpayers

Poland: “Cooperation program” for large taxpayers

The Polish Senate approved legislation introducing a “cooperation program” that would exist between large taxpayers and the tax administration.


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The cooperative program is expected to be effective beginning July 2020, and would be available to eligible taxpayers with revenues exceeded €50 million in the previous tax year.

The benefits for taxpayers that decide to take part in the cooperative program would include:

  • The head of the tax administration would be the only authority able to perform a tax audit of the taxpayer.
  • The form and frequency of tax audits of each taxpayer would consider the internal tax procedures, as well as evolution of cooperation between the taxpayer and tax authorities.
  • In instances when tax liabilities are understated, there would be an assumption of the taxpayer’s “goodwill.”
  • The participant of the cooperative program would not be subject to the mandatory disclosure rules as a beneficiary in relation to domestic tax schemes.
  • Program participants would be able to enter into tax agreements with the head of the tax administration (including tax rulings, APAs, protective opinions among others) within a simplified and less-expensive procedure.

The requirements to take part in the program include: (1) revenues greater than €50 million in the previous tax year; (2) the taxpayer must enter into a cooperation agreement with the head of the tax administration; (3) the taxpayer will be subject to an initial tax audit for the year of application plus two previous years; and (4) the taxpayer will be required to introduce internal tax procedures, correctly satisfy its tax obligations, and report any disputed tax issues to the head of the tax administration.

Read a November 2019 report prepared by the KPMG member firm in Switzerland

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