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19 January 20224 minute read

DLA Piper Poland's tax team summarises the challenges for 2022

With the beginning of the year, we would like to present the most important tax changes that have come into force in Poland and that will significantly affect the economic and fiscal activities of companies and entrepreneurs in 2022. Below we present those of which DLA Piper Poland’s tax advisors pay particular attention to:

  • Minimum income tax for CIT taxpayers;
  • New formula for the so-called “Estonian CIT” allowing for deferment of tax liability until the dividend is paid to shareholders;
  • Stricter thin capitalisation rules;
  • Introduction of the “pay and refund” procedure on withholding tax collected on payments to related parties;
  • Parent-subsidiary exemption for capital gains in share deal transactions for a new category of entities – “holding companies”;
  • Non-deductibility of health insurance contributions for PIT purposes (applicable for employees, as well as entrepreneurs running businesses as sole traders).

Planned further changes are:

  • Restrictions in tax deductibility of hidden dividends;
  • Increase of the non-deductible health insurance contribution for sole traders who elected flat 19% PIT taxation of business income.

All members of DLA Piper's tax team in Warsaw represent a unique combination of tax, legal and economic expertise. Their work covers all areas, from tax structuring and regulation to ongoing assistance, securitisation and financing.

Led by partner Bartosz Matusik, the team consists of nine lawyers and tax advisors. In November 2021, a new partner, Łukasz Dynysiuk, joined. He advises Polish and international clients on the corporate and tax aspects of M&A transactions and corporate restructuring processes. In November 2021 and in January 2022 respectively, the team gained two experienced senior associates: Małgorzata Krok, and Rafał Dostatni. Their addition to the Warsaw office expanded the team's capabilities, creating a stronger platform to serve existing and new clients in Poland and the CEE region.