tax law
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CJEU: Poland’s conditions for bad debt relief are too strict
The mechanism known as ‘bad debt relief’ allows the taxpayer (creditor) to adjust the VAT taxable amount and the VAT due. To do so, the business must satisfy the conditions set out in Article 89a of the VAT Act, as follows:
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Investment fiduciary arrangements — confidentiality and the limits of anonymity
A fiduciary arrangement can separate formal rights from an investor’s economic interest. It does not, however, ensure anonymity or automatically exclude AML and Central Register of Beneficial Owners (CRBR) obligations.
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Share exchanges — the dispute over tax neutrality
The tax exemption for share exchanges, set out in Polish law in Article 24(8a) of the Personal Income Tax Act and Article 12(4d) of the Corporate Income Tax Act respectively, perfectly illustrates a situation in which the way a transaction is carried out…