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Poland: Mandatory disclosure rules, cross-border tax planning arrangements

Poland, mandatory disclosure rules effective 2019

New tax law in Poland, published 23 November 2018 in the journal of laws, includes mandatory disclosure rules that generally reflect an EU Directive (known as "DAC6") for disclosure of cross-border tax planning arrangements.


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Now that the legislative process in Poland for the mandatory disclosure rules has been finalized, the Ministry of Finance has initiated public consultations for guidelines to implement the new rules. 

The rules in Poland are not limited to "aggressive" tax planning or tax avoidance elements, but apply broadly to all tax arrangements that satisfy the hallmarks of the Polish legislation. Also, in Poland, the effective date is 1 January 2019 (and not 1 July 2020 as under DAC6).


Read a November 2018 report [PDF 516 KB] prepared by the KPMG member firm in Poland

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