• Service: Tax, International Corporate Tax, Global Compliance Management Services
  • Type: Regulatory update
  • Date: 7/7/2014

Poland - Status of CFC legislative proposals 

July 7: Legislative proposals in Poland include measures for a controlled foreign corporation (CFC) regime, under which tax would be imposed on certain income or gains derived by certain foreign subsidiaries owned by Polish taxpayers.

The pending legislative proposals define when a subsidiary would be considered to be a CFC.

The legislation also, if enacted, would make changes to the thin capitalization rules and the tax treatment of in-kind transfers of assets to shareholders.

Status of legislation

The lower chamber (Sejm) passed the bill in late June 2014, thus sending the measures to the upper chamber of the parliament. After the completion of the legislative procedures in both chambers, the bill would be presented to the president for signature.

The CFC provisions are intended to be effective on the first day of the fourth month following official promulgation of the law—which means that if the legislation were to be published in July 2014, the CFC rules would be effective beginning November 2014.

Read a July 2014 report(PDF 138KB) prepared by the KPMG member firm in Poland: Tax Alert (July 2014)

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