Poland: Guidance on tax rulings (Supreme Administrative Court decisions)
Summaries of decisions of the Supreme Administrative Court
Summaries of decisions of the Supreme Administrative Court
The KPMG member firm in Poland prepared a report that includes summaries of the following decisions of the Supreme Administrative Court issued on 11 January 2023:
- The court held (case file II FSK 1241/22) that a company that establishes a tax group with other entities may still enjoy the protective force of tax rulings obtained before the formation.
- The court held (case file II FSK 1238/22) that a municipality could apply for a ruling on tax scheme reporting requirements.
The report also included a summary of a clearance opinion dated 20 December 2022 and published 12 January 2023 (case file DKP3.8082.12.2022), allowing a taxpayer to engage in an arrangement involving the early partial repayment of loans by selected related entities and allocation of these repayments in full to repayment of the principal of these loans (and not interest).
Read a January 2023 report prepared by the KPMG member firm in Poland
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