Poland MOF Issues Guidance Clarifying Shifted Income Tax Provisions

The Polish Ministry of Finance Sept. 15 issued a guidance clarifying the application of shifted income tax provisions under the Corporate Income Tax Act. Topics covered include: 1) the purpose and scope of the shifted income tax provisions, and the conditions for treating costs transferred between related entities as shifted income; 2) the criteria for determining whether a nonresident entity meets the conditions for low taxation, primary income source, and income transfers by intermediaries; 3) a safe harbor provision exempting taxpayers from shifted income tax if costs incurred for intangible assets, royalties, and debt financing don’t exceed 3 percent of ...