Does a holding company run a (real) economic activity?

Does a holding company run a (real) economic activity?

So far, the issue of holding companies conducting real economic activity has not been subject of lively discussions in Poland. Nevertheless, the provisions introduced by the legislator as a weapon to fight tax avoidance, in particular the provisions on controlled foreign companies (CFC) and the new rules for collecting withholding ... Read More »

Legislative proposal for the modernisation of partnerships; civil and tax aspects

Legislative proposal for the modernisation of partnerships; civil and tax aspects

On 21 February, the draft bill of the Legislative Proposal for the modernisation of partnerships (‘draft legislative proposal’) was submitted for consultation. The draft legislative proposal intends to provide a modern, clear and straight forward scheme that, on the one hand facilitates the entrepreneur and, on the other, offers suitable ... Read More »

New Italian Tax Regime For Pensioner

New Italian Tax Regime For Pensioner

1 Foreword This article aims to illustrate the introduction of a new tax regime provided by the Italian Government to attract foreigners and Italians in retirement living in foreign countries to move their residence to Southern Italy. 2 The new Italian tax regime for pensioners On the 30th of December, ... Read More »

Capital gains realized from the disposal of stocks in a Polish joint-stock company are taxable only in a transferor’s state of residence

Capital gains realized from the disposal of stocks in a Polish joint-stock company are taxable only in a transferor’s state of residence

Albert Einstein once said that a question pertaining to taxes is too difficult for a mathematician. It should be asked of a philosopher. Unfortunately, the world famous physicist did not take into account that practicing philosophy with reference to this field of law can very easily lead to the omission ... Read More »

Central Register of Beneficial Owners in Poland – private foundation is in question

Central Register of Beneficial Owners in Poland – private foundation is in question

Foreign private foundations are becoming more and more popular among Poles as an instrument of inheritance planning and private assets protection. Polish Act on Counteracting Money Laundering and Terrorist Financing (“AML Act”) obliges Polish commercial law companies to report information about their Beneficial Owners to the Central Register of Beneficial ... Read More »

The favourable tax regime of new Italian residents

The favourable tax regime of new Italian residents

Foreword This brochure aims to illustrate the introduction of the new tax regime for the “new Italian residents” with the debut of a lump-sum taxation called “Flat tax”, granting an exemption of foreign investments from Italian taxation, called “non-domiciled tax resident”. The Italian Finance Bill for 2017 (hereinafter “Finance Bill”) ... Read More »

Amendment of the Czech Labour Code regarding the cancelation of the so-called suspensive time clause

Amendment of the Czech Labour Code regarding the cancelation of the so-called suspensive time clause

Labour Law Alert: Cancelation of the suspensive time clause I. Cancelation of the suspensive time clause As of 1 July 2019 the Amendment of the Czech Labour Code (i.e. the Act No. 32/2019 Coll., amending the Act No. 262/2006 Coll., Labour Code, as amended) has become effective. The new legislation ... Read More »

Italian Patent Box

Italian Patent Box

The Italian Finance Bill for 2015 has enhanced an important provision named “Patent Box”, to facilitate and attract foreign taxpayers, improve the Research and Development in Italy and most important preserve the “i.e. Made in Italy”. This provision introduced in Italy is an optional tax regime, that allows reduced taxation ... Read More »

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