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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 »

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 »

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