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Poland's Pending Anti-Avoidance Provisions

28 March 2014

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Proposed Changes

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Poland

Significant focus is given to anti-avoidance in Poland's pending legislation to amend the Tax Ordinance Act and other Acts. Poland's Ministry of Finance explained that the legislation is intended to streamline tax proceedings and insulate the tax collection process. Two of the main aspects of the legislation include new general anti-avoidance regulations (GAAR) and controlled foreign company (CFC) regulations. GAAR The GAAR in the proposed legislation allows the tax authorities to determine the tax liability based on the real nature of a transaction when a taxpayer is deemed to have performed an artificial transaction with the main purpose of obtaining...