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Poland: “Exit tax” when business is transferred to another country

Poland: “Exit tax”

Regulations for implementing an “exit tax” intend that unrealized, potential gains resulting from the transfer of business from Poland to another country are subject to tax in Poland. The new regulations are intended to allow the authorities to tax the economic value of any potential capital gains that would have been realized if the transfer had not taken place.


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The Polish regulations regarding exit taxation flow from the Council Directive (EU) 2016/1164 (known as the “anti-tax avoidance directive” or ATAD). Exit taxation is one of the solutions included in ATAD, and a fundamental aim is to provide tax is paid where profits and value are generated. 


Read a July 2018 report [PDF 375 KB] prepared by the KPMG member firm in Poland

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