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Poland to Introduce Tax on Shifted Profits and Amendments to CFC Rules to Extend Scope of Passive Income Condition and Tighten Low-Tax Condition

|Proposed Changes|Poland
Poland

The Polish government has proposed the introduction of a tax on shifted profits as part of the so-called "Polish Deal" tax reform. The tax would be levied at a rate of 19% (corporate rate) on costs incurred, directly or indirectly, for the benefit of a related party that constitutes a receivable for the related party (i.e., payments to a related party) if the following conditions are met:

  • The related party is subject to low tax in its jurisdiction of residence, meaning the actual income tax …

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