Contact
dr hab. / dr Marcin Jamroży

Steuerberater (Polen), Rechtsanwalt (Polen)
Partner
Phone: +48 22 244 00 20
E-Mail

Anti-Tax Avoidance Clause
– the form and implications

Marcin Jamroży, Anna Główka, Iwona Łaska-Rutkowska, Monika Spotowska

Published by: ODDK Gdansk
Published in: 2016
Pages: 282
ISBN: 978-83-7804-323-2

The book presents new regulations in force since 15 July 2016, with a particular focus on: 

  • rationale for the tax avoidance – what can make a transaction liable to that clause, what does the concept of "artificial operations" mean, how to understand an illegal "tax advantage"
  • consequences of the tax avoidance, and tax assessment decisions by tax authorities
  • tax proceedings in the case of tax avoidance
  • powers and rules of operation of the Anti-Tax Avoidance Council
  • business clearance certificates for taxpayers to protect their transactions from classification as tax avoidance attempts.

In addition, the book includes the consolidated text of the Polish Tax Act with highlighted amendments which introduce the anti-tax avoidance clause. 

VAT 2015. Commentary for practitioners (including an electronic supplement)

Authors: Katarzyna Judkowiak (ed.), Halina Lebrand (ed.), Justyna Pomorska

Publisher: ODDK
Edition: 2/2015
ISBN: 978-83-7804-231-0
Ordering: ODDK

VAT 2015. Komentarz dla praktyków (z suplementem elektronicznym) [VAT 2015. Commentary for practitioners (including an electronic supplement)] is yet another in-depth publication by Katarzyna Judkowiak, Halina Lebrand and Justyna Pomorska. It describes the most up-to-date legal status (01/04/2015) and discusses the legislation at length quoting various examples and tips on the best practices. The book also refers to the most recent judgements of the Supreme Administrative Court, the Provincial Administrative Courts, the Court of Justice of the European Union, the tax authorities and advance tax rulings of the Finance Ministry.

The Commentary can help you sort out specific problems with applying the current provisions of the VAT Act concerning:

  • recognition of tax liability;
  • invoicing;
  • taxable base and adjustment of taxable base under the regulations introduced in 2014;
  • deduction of input VAT.

The electronic supplement accompanying this publication contains:

  • the content of the commentary to the VAT Act;
  • the consolidated text of the Value Added Tax Act;
  • the appendices to that act;
  • a whole set of up-to-date regulations of the Finance Minister;
  • the EU legislation: the VAT Directive 2006/112/EC, the Council Regulation (EC) No 282/2011 of 15 March 2011 laying down implementing measures for that directive.

Operating in a Special Economic Zone. Legal and Tax Aspects

[Funkcjonowanie przedsiębiorstw w specjalnej strefie ekonomicznej. Aspekty prawne i podatkowe]

Authors: D. Białas, M. Gosek, dr hab. M. Jamroży, M. Kapera, R. Papała, M. Przybył, A. Smagowicz-Tokarz, M. Spotowska, P. Wojszczyk 

Publishing House: C.H. Beck
ISBN: 978-83-255-7186-3
Edition: 1, 2015
Ordering: C.H. Beck 

Operating in a Special Economic Zone. Legal and Tax Aspects is a publication prepared by Rödl & Partner's experts who discuss at length the legal and tax regulations of doing business in special economic zones. The book considers the most recent legal status and is based on the still-applicable Special Economic Zones Act of 20 October 1994. It also discusses the planned amendments concerning, among other things, regulations on returning the state aid, grounds for requests to declare a zone permit expired as well as an option to let the enterprise ask for the zone permit to be revoked. With widely cited court judgements, advance tax rulings and numerous examples and case studies the readers will have a chance to find a practical solution to some of the problems they encounter in applying the tax law.

Taxation of company cars in business (PIT, CIT, VAT)

[Opodatkowanie samochodów służbowych w działalności gospodarczej (PIT, CIT, VAT)]

Authors: Białas Dorota, Krawczyk Michał

Publishing House: C.H. Beck
ISBN: 978-83-255-6656-2
Edition: 1, 2014
Ordering: C.H. Beck 

The book co-authored by Dorota Białas describes in detail the recent changes in accounting for expenses of using cars in a business activity. The publication outlines the accounting solutions that help enterprises to optimise and streamline their tax issues and are accepted by the tax authorities.

The book is divided into chapters about:

  • Changes to the Value Added Tax Act.
  • Abandonment of VAT-23, VAT-24 and VAT-25 certificates.
  • Changes concerning the personal income tax.
  • Changes concerning the corporate income tax.
  • Transitional provisions for changes in the Personal Income Tax Act and the Corporate Income Tax Act.
  • Implications of the changes to the VAT Act for income taxes.
  • Guidance by the tax authorities.
  • Supplement. VAT deductions on car expenses in the European Union.

The publication covers as well the latest amendment to the Value Added Tax Act of 11/03/2004 (consolidated text in Journal of Laws of 2011, item 1054, as amended) which deals with accounting for VAT on the acquisition and use of passenger cars and motor vehicles with a permissible total weight of up to 3.5 tonnes. The changes came into force on 01/04/2014.

The book is addressed to broad audience. It will be particularly useful for practitioners such as tax advisers, civil servants, accountants, economists and attorneys at law.

Transfer pricing documentation

Authors: Dr Marcin Jamroży (ed.)

Publisher: ODDK, 2014
Edition II
ISBN: 978-83-7804-190-0
Price: PLN  170,00 net
Ordering: ODDK

The updated second edition of "Transfer pricing documentation" edited by Dr. Marcin Jamroży contains information necessary for the preparation of tax documentation concerning transactions between related parties, advising at the same time on the possibilities to limit transfer pricing risks. The explanations are accompanied by numerous examples of tax documentation for different types of transactions, and are supplemented by the description of relevant procedures and instructions.

The book also outlines issues relating to the principles of applying the methods for estimating the arm's length value in restructuring processes, in particular those regarding the transfer of economic functions abroad, as well es selected aspects of tax and inspection proceedings regarding transfer prices and of instruments limiting the tax risk. The authors also point to risks arising in tax settlements of related parties.

VAT 2014. Commentary for Practitioners (including an electronic supplement)

Authors: Katarzyna Judkowiak (ed.), Halina Lebrand (ed.), Justyna Pomorska

Publisher: ODDK
Edition: 2014
ISBN: 978-83-7804-177-1
Price: PLN  220,00 net
Ordering: ODDK

The new publication of Katarzyna Judkowiak, Halina Lebrand and Justyna Pomorska, dealing with the amendments to the Value Added Tax (VAT) Act made in 2014, contains a thorough commentary on every article of the Act and illustrates, on the basis of examples, complicated legal structures. The book presents amendments introduced in 2014 and contains interpretations of new regulations, so far not published rulings of administrative courts (Supreme Administrative Court and Provincial Administrative Court), issued after the publication of the Act, as well as decisions of tax authorities, advance tax rulings of the Minister of Finance and the doctrine of law. Moreover, the authors give practical guidance as regards the rules of deductibility of tax on expenses on cars, taking into account the most recent guidelines of the Ministry of Finance. The book is accompanied by an electronic supplement which is very useful in practice.

VAT - instruction on settlement with examples

Authors: Katarzyna Judkowiak, 

Publisher: ODDK
Edition: 2014
ISBN: 978-83-7804-207-5
Price: PLN  150,00 net
Ordering: ODDK

"VAT - instruction on settlement with examples" by Katarzyna Judkowiak is an indispensable instruction in every company, describing in detail the rules for implementing the new principles for the determination, documentation, recording and declaration of  the Value Added Tax after the latest amendments of the Act. 

Numerous amendments to the Act, introduced in 2014, are causing many problems to the taxpayers. In her book, the author explains these problems detail, referring at the same time to practical examples. You can find here exhaustive information about:

  • tax point (general principle and special principles)
  • taxable base
  • tax rates
  • new amendments on invoicing
  • input VAT
  • tax returns.

Value Added Tax Act.

Umsatzsteuergesetz

C.H. Beck Warsaw
Edition: III.
Publlication date: 2014
ISBN: 978-83-255-6469-8
Price: PLN  199,00 net
Ordering: C.H. Beck

Translated by: Rödl & Partner 

The third edition of the German translation of the Polish Value Added Tax Act takes into account the latest amendments to the Act which have been in force since 01/04/2014.The freuquency, type and scope of amendments to tax legislation cause serious problems for entrepreneurs making investments in Poland. Thus, it is necessary to regularly monitor both the amendments to the legislation and consequences arising from it. Therefore, we continue the series of translations of Polish acts into German started by us in 2004, and hope that this translation helps a wide group of its recipients not only to overcome the language barrier but also to better understand Polish tax regulations, and thus encourages them to start business activity in Poland.

Car in a company Instruction on VAT, CIT and PIT taxation Sample regulation on the use of cars for mixed purposes (along with electronic supplement)

Authors: Katarzyna Judkowiak, Justyna Pomorska

Publisher: ODDK
Edition: 2014
ISBN: 978-83-7804-211-2
Price: PLN  150,00 net
Ordering: ODDK

Instruction on practical tax aspects (VAT, PIT, CIT) of using cars for business purposes by taxable persons in the context of the latest amendments to tax acts, including:

  • instruction on how to deduct the input VAT on the purchase of cars and how to use cars on the basis of lease agreements
  • rules for the deduction of input tax on car use expenses 
  • new methods for the correction of input tax in case of changing the intended use of the car
  • rules for the taxation of the sale of cars, including used cars
  • recording car-related expenses, including VAT amounts, according to income tax regulations

The authors comment in clear and precise words on the new amendments to the method for the deduction of tax on cars and provide concrete examples, which makes their approach very practice-oriented. 

Especially valuable is the enclosed sample regulation on the use of cars for mixed purposes along with relevant documentation. It can be very helpful in implementing specific solutions in a company and in case of a tax inspection.

Lease of Commercial Space. Legal, Tax and Accounting Aspects

Authors: Tomasz Balcerak, Anna Główka, Marcin Jamroży, Katarzyna Judkowiak, Renata Kabas-Komorniczak, Grzegorz Stachyra

Publisher: ODDK, 2013
ISBN: 978-83-7804-095-8
Price: PLN  150,00 net
Ordering: ODDK

Lease of Commercial Space. Legal, Tax and Accounting Aspects [Najem lokali użytkowych. Aspekty prawne, podatkowe i rachunkowe] is the newest publication edited by Marcin Jamroży, which contains a thorough analysis of commercial space lease ranging from the lease agreement through to taxation with income tax, VAT and real property tax, through to accounting aspects such as recognition in the books of account, revenues and expenses, appraisal and reclassification of real property, and lease fee calculation. The analysis is accompanied by practical examples which make the publication clear and easy to understand, and a source of valuable knowledge for financial and accounting directors as well as lawyers, tax advisers and auditors.

VAT 2013/2014
Commentary for Practitioners (including an electronic supplement)

Authors: Katarzyna Judkowiak (editor), Halina Lebrand (editor), Justyna Pomorska

Publisher: ODDK, 2013
ISBN: 978-83-7804-045-3
Price: PLN 220.00 net
Ordering: ODDK

This publication combines an in-depth analysis of the VAT Act with practical examples from many years of the authors' experience, court judgements and advance tax rulings issued by the Ministry of Finance. The commentary explains the new issues arising from the amendments to the VAT Act which entered into force on 1 January 2013, 1 April 2013 and those scheduled to enter into force on 1 January 2014. You will find the clarification of problems concerning invoicing, invoice adjustment, changes in cash register accounting, new tax rates, goods given free of charge for promotion and advertising purposes, goods export and many other issues. This combination makes the book an invaluable source of knowledge for all practitioners and people who struggle with interpretation of the VAT Act in their daily work.

The electronic supplement accompanying this publication contains the annexes to the VAT Act, the consolidated texts of the VAT Act and regulations to this act with the most recent amendments highlighted, the new Regulation of the Minister of Finance of 14 March 2013 concerning cash registers, the VAT Directive 2006/112/EC and the EU Regulation No. 282/2011 of 15 March 2011 laying down implementing measures for that Directive.

Rzeczowe aktywa trwałe. Zasady ujmowania, wyceny oraz ujawnień w świetle uregulowań MSSF/MSR i ustawy o rachunkowości

Editorial staff: Rafał Sobczyk, Agnieszka Regulska
Publisher: ODDK, 2012
ISBN: 978-83-7804-040-8
Price: PLN 220,00 netto
Orders: ODDK

This publication covers the rules for recognition and valuation of property, plant and equipment in compliance with IAS/IFRS regulations, IFRIC interpretations, the Accounting Act and the national accounting standards (including but not limited to initial valuation, valuation after recognition, amortisation and depreciation, impairment, deletion of any given asset, reclassification of property, plant and equipment). The publication also includes a detailed presentation of the requirements concerning the disclosure of additional information about those assets in the financial statements. 

Nearly half of the book is devoted to real-life examples of the transactions and business events which its authors encountered in their long-standing professional career. The examples illustrate practically all guidelines included in individual IAS 16 paragraphs and other standards described in this publication. 

Furthermore, any discrepancies between IAS/IFRS regulations and the provisions of the Accounting Act were supported with examples which make it possible to better understand the substance and the meaning of those discrepancies.

The publication was prepared according to the legal status and the standards in the version applicable as of 01.01.2012, whereas the standards and interpretations described in the book are those adopted by the EU.

 

A commercial law partnership

Editorial staff: Marcin Jamroży, Agnieszka Jamroży
Publisher: ODDK, 2011
ISBN: 978-83-7804-006-4
Price: PLN 84,60netto 
Orders: Wolters Kluwer Polska ABC  

This publication includes not only a study of formation, operation and termination of partnerships (general, professional, limited partnerships), but also a narrative description of many other issues, including civil law partnerships (also the silent one), European economic interest groupings, as well as a selection of unincorporated bodies. There are very few publications available in the market, which deal with tax aspects of  those legal forms of business. Consequently, this must be one of the very first publications which not only attempt but indeed discuss this difficult, yet fascinating problem for the business people.

The publication is intended for tax advisers, attorneys at law, auditors, and managers. 

 

Employment of foreigners in Poland

Editorial staff: Marcin Jamroży, Tomasz Major, Beata Pawłowska, Monika Spotowska
Publisher: ODDK, 2011
ISBN: 978-83-7804-006-4
Price: PLN 150,00netto 
Orders: ODDK 

It is a detailed and practical instruction for businesses that second foreigners to work in Poland or employ foreigners in Poland.
The globalisation process has prompted a growing interest in recruiting foreign employees in Poland. The number of foreign managers and medium level personnel working in Polish companies and Polish branches of foreign businesses has grown noticeably.
This publication deals with all most important aspects of the work performed in Poland by foreigners. The authors describe the issues of work legalisation, taxation, contracts, and social insurance of that group in an accessible and exhaustive way, and present numerous examples of the possible states of affairs and legal situations.

 

The construction contract

Editorial staff: Marcin Jamroży, Przemysław Fil, Agnieszka Jamroży, Halina Lebrand
Publisher: ODDK, 2011
ISBN: 978-83-7804-010-1
Price: PLN 160,00netto 
Orders: ODDK

The newest publication prepared by Rödl & Partner experts is a detailed and practical study of tax issues referring to performance of construction contracts and arising from application of income tax acts, double taxation avoidance agreements, and the VAT Act. 

The book begins with a legal study of a construction contract, whereas the final chapter deals with recognition and valuation of long-term contracts in line with the accounting law The deliberations are supported by numerous examples from the authors' everyday practice.

This publication is intended mainly for practitioners operating in the construction and assembly industry, as well as CFOs, accountants, controllers, lawyers, tax advisers and certified auditors.

VAT 2011 Commentary on amendments – consolidated text of the act with highlighted amendments; new executive regulation

Author: Katarzyna Judkowiak
Publisher:  ODDK, 2011
ISBN: 978-83-7426-723-6
Price: PLN 140,00netto 
Orders:ODDK

Practical and example-backed review of changes in the Goods and Services Tax Act binding in 2011, such as:

  • changes in VAT rates;
  • new tax exemptions – changes in structure of the regulations;
  • gratuitous transfer of goods – changes in the methods of accounting for;
  • full deduction of input VAT when the ratio for determining deductible input VAT amount exceeds 98%, but is no more than PLN 500;
  • departure from the ban on deducting input VAT wherever the share of the taxable sales in the total sales did not exceed 2% in the previous year;
  • changes with respect to passenger cars equipped with a cargo partition;
  • new rules with respect to cash registers;
  • new definitions (e.g. with respect to goods, new means of transport).

Hints on how to use new opportunities and privileges concerning VAT accounting, along with traps that may be encountered. Numerous practical remarks and consolidated text of the VAT act with highlighted amendments, supplemented with 10 most up-to-date and most frequently used regulations – all as an indispensable help in every company.

2011 Taxes – Consolidated texts of the VAT, PIT and CIT Acts with practical commentary by Rödl & Partner experts

Authors: Dorota Białas, Krzysztof Biernacki, Jarosław Hein, Aleksandra Majnusz
Publisher: Wiedza i Praktyka, 2011
ISBN: 978-83-269-0372-4
Price: PLN 200,00 netto 
Orders: WiP

If you account for the VAT, PIT or CIT you most certainly know that the raw text of a consolidated act is not enough to cope with the challenges posed by the new regulations. Even more so that the new tax regulations bring about a host of completely new consequences for your work. This book will provide you with a sense of security and will help you quickly and comfortably prepare for changes in the VAT, PIT and CIT Acts.

In this book, you will find

  • the most recent, consolidated by the editorial staff, versions of the acts,
  • practical comments by Rödl & Partner experts indicating consequences for your work,
  • the executive regulation and the regulation concerning invoices accompanying the VAT Act,
  • consolidated texts of the acts and the most significant executive regulations to the VAT, PIT and CIT Acts in electronic version.

Transfer pricing documentation

Editorial staff: dr Marcin Jamroży

Author: Anna Główka Anna Harasimowicz, Marcin Jeliński, Ewa Kubów, Katarzyna Łysiak, Małgorzata Ostrowska-Krzewina, Renata Papała,
Dr. Christian Rödl, Michael Scharf, Marcin Sobieszek, Anna Wydra

Publisher: ODDK, 2010
Number of pages: 462
ISBN: 83-74266-90-1
Price PLN 150,00
Orders: ODDK

The publication provides the information necessary for preparation of tax documentation concerning transactions concluded between related parties, advising at the same time on the possibilities to limit the risk related with transfer pricing.  

According to the review by Prof. dr hab. Bogusław Pietrzak from the Fiscal Policy Department at the Collegium of Social and Economic Science of the Warsaw School of Economics (...)”The authors of the book have managed to present both the general issues mentioned in the title and the particular issues relating to the nature of individual areas of activities undertaken by related entities in a reader-friendly manner.”(...).

The book’s important advantage from the practical viewpoint are numerous examples of tax documentation, procedures, questionnaires or instructions. Those examples are available owing to the knowledge and experience of Rödl & Partner experts, whose professional practice consists in advising in, among others, tax documentation and transfer pricing.   

 

Reducing the tax burden

Tax advisers (Marcin Jamroży (PhD) and Marcin Sobieszek) apply an interesting and pragmatic approach to analysing various areas of business operations and point out how to reduce the tax burden in a given area. The market premiere of the book Obniżanie ciężarów podatkowych The book has been published in co-operation with ODDK Publishing House in Gdansk. The authors, tax advisers at Rödl & Partner, also elaborate on running a business activity in special economic zones, and through a foreign permanent establishment or a foreign daughter company. All the discussed issues are supported by practical examples, court judgements, and interpretations of tax authorities.

Author: Marcin Jamroży (PhD) and Marcin Sobieszek

Publisher: ODDK, 2010
Number of pages: 208
ISBN: 83-74266-83-3
Price: PLN 120,00
Orders: ODDK

VAT 2010 - Komentarz do zmian [VAT 2010 – Commentary on amendments]

Study of practical effects brought about by amendments to the Polish Goods and Services Tax Act, as introduced by statutes dated 23 October 2009 and 2 December 2009 and referring to the rules of determining the place of performance (and consequently – taxation) of services, recognition of the tax obligation due to import of continuous services, rules of settling intra-Community supplies of goods by taxpayers submitting tax declarations on a monthly basis, time limits and rules of preparation of EC Sales Lists, refund of input VAT charged from foreign entities not registered for VAT purposes in Poland, and refund of foreign value added tax to Polish entities, exemptions from the obligation to use cash registers as well as an increase in the limit of turnover.

Bringing up examples, the authors, specialists at Rödl & Partner, present new opportunities and facilitations as regards VAT settlements, and point to the possible circumstances which may entrap entrepreneurs. Numerous working remarks and the consolidated text of the Act, with the introduced amendments highlighted, make up an indispensable tool for every business.

Authors: Katarzyna Judkowiak, Halina Lebrand
Publisher: ODDK,
Format: B5, paperback
Number of pages: 304
ISBN: 83-74266-56-7
Price: PLN 70,00
Orders: oddk
Contact to the editor, Ewa Góra: Ewa.Gora‎‎@‎‎oddk.pl

 

Europejskie prawo spółek - Tom IV. Spółki zagraniczne w Polsce [European Corporate Law – Vol. 4. Foreign Companies in Poland]

The fourth volume of the "Europejskiego prawa spółek" deals with legal institutions applicable to foreign companies which enjoy the freedom of establishment and operate in Poland. Due to the freedom of establishment, it is possible for companies coming from other Member States to relocate their registered offices and set up daughter companies, branches, agencies and offices in Poland. Under the freedom of establishment, foreign businesses may also participate in restructuring processes (mergers, demergers), including cases where a Polish company is an acquiring or a newly-established company. The freedom of establishment is reinforced with prohibition of restricting the same, i.e. a ban under which the Member States (including Poland) are banned from the use of measures which, according to the European Court of Justice, may hinder the freedom of establishment or discourage to execute the same.

The authors of individual chapters have attempted to answer the question of how investment-friendly the Polish law is for foreign companies and whether it hinders the freedom of establishment.

Dr. Marcin Jamro¿y is the author of the chapter titled Orzecznictwo ETS w zakresie opodatkowania dochodów spółek (ECJ rulings on taxation of company's revenues

The book is addressed to a broad audience, particularly to people who deal with the regulations on foreign companies established in Poland in their everyday practice.  

Authors:
Professor Jacek Napierała
Dr. Marcin Jamroży
Aleksandra Gawrysiak-Zabłocka,
Tomasz Targosz,
Dr. Wojciech Klyta,
Dr. Paweł Grzegorczyk,
Jędrzej Jarzmanowski,
Dr. Krzysztof Oplustila,
Dr. Marcin Spyra

Publisher: Wolters Kluwer Polska – ABC, 2008
Format: hardback
Number of pages: 412
ISBN: 978-83-7526-822-5
Price: PLN 99,00
Warsaw 2008, 1st edition
Orders: Wolters Kluwer Polska –.proinfo.pl

Inwestowanie w Polsce [Investing in Poland]

Frame tax and legal requirements to be met by German companies, including recommendation on structuring.

”Inwestowanie w Polsce” is a study essential for (prospective) investors in Poland and their advisors. It provides the most up-to-date, extensive and practical information on all issues relevant for business in Poland.

The basic topics covered in the book include the tax law, accounting law and corporate law, particularly acquisition of companies and real property in Poland by foreign investors, personal income tax, corporate income tax, new double taxation avoidance agreement between Poland and Germany, sales taxes (VAT and civil law transaction tax), outline of the tax proceeding regulations, penal fiscal law in Poland, domestic and corporate transboundary financing etc.

Another great advantage of the book is the editorial team which includes extraordinarily competent experts with excellent knowledge of the local conditions. Authors of individual chapters draw on their many-year service with Rödl & Partner and vast experience in the advisory practice.

Editorial staff:
Professor Stephan Kudert, Europa-Universität Viadrina, Frankfurt (Oder)

Publisher: Erich Schmidt Verlag, 2007
Format: 15.8 x 23.5 cm
Number of pages: 891
ISBN : 978-3-503-09798-2
Price: EUR 86,00 + shipping and handling
Orders: Erich Schmidt Verlag

Optymalizacja opodatkowania dochodów przedsiębiorców [Tax optimisation of company’s revenue]

"Optymalizacja opodatkowania dochodów przedsiębiorców” is a study of the way in which taxation affects typical business decisions.

Chapter 1 presents economic effects of taxation and the issues related to structuring tax burdens and including taxes in the decision-making process, whereas Chapter 2 illustrates methods of measuring suhc tax burdens. Chapters 3-7 and 8-11 make up an analysis of day-to-day as well as strategic business decisions.

Authors:
Professor Stephan Kudert, Europa-Universität Viadrina, Frankfurt (Oder)
Dr. Marcin Jamroży

Publisher: Wolters Kluwer Polska – ABC, 2007
Format: 14.5cm x 20.5cm, booklet binding
Number of pages: 280
ISBN: 83-7526-395-4
Price: PLN 59,00
Orders: Wolters Kluwer Polska – ABC

Umowa o unikaniu podwójnego opodatkowania z Niemcami – komentarz [Double Taxation Avoidance Agreement with Germany – Commentary]

The new double taxation avoidance agreement between Poland and Germany has been basically in force since 1 January 2005. The agreement sets forth provisions that depart from the content and effect of the provisions under the agreement effective since 1972 until recently.  The new agreement provides for withholding tax (with certain exceptions) on disbursed interest as well as on license-based liabilities. The possibility for the other party to the transaction to correct the tax amount in case the transfer pricing is called into questions is a matter from the point of view of related companies. Taxation-related amendments refer also to the members of the management board and employees seconded to work in another country.

Poland and Germany are to support each other in enforcing tax liabilities.

It is difficult to overestimate the significance of the agreement for economic relations between the two countries especially that for many years now German businesses have been top-ranked foreign investors in Poland as far as the investment value and the number of investors are concerned.

Provisions of the agreement reviewed in this book have been subject to a thorough study to pinpoint working tax consequences for the Polish and German companies. The publication constitutes an attempt to address the doubts that emerge during application of the agreement. The issues are presented possibly in the most accessible manner and illustrated with examples. Efforts have been made to include the relevant regulations of the domestic Polish and German tax law in the comments.

Editorial staff:
Dr. Marcin Jamroży, Tax Adviser
Dr. Adrian Cloer, Attorney at Law

Publisher: C.H. Beck, 2006
Format: 140 x 218 mm
Number of pages: 670
ISBN : 83-7483-261-4
Price: PLN 119,00
Orders: C.H. Beck

Opodatkowanie spółki osobowej [Taxation of partnerships]

Review:

“The Polish professional literature is short of monographs on international tax law, especially as regards the issues of double taxation avoidance in the light of international treaties. At the same time, the demand for such studies is huge among the working professionals (…). Therefore, the doctoral dissertation under the review is one of the few papers in the Polish professional literature which elaborates on the legal position of partnerships (their rights and obligations) as regards taxation of revenue.” Professor Jerzy Małecki (Adam Mickiewicz University in Poznan).

“Tax-related issues that refer to operation of companies having no legal personality under domestic or international laws are material from the theoretical and practical perspective, intellectually interesting and appealing though difficult.” Professor Włodzimierz Nykiel (University of Lodz).

Author: Dr. Marcin Jamroży, tax adviser  
Publisher: CH Beck, 2005
Number of pages: 194
ISBN : 83-7387-669-3
Price: PLN 45,00
Orders: C.H. Beck

Ceny transferowe w planowaniu podatkowym – [Transfer pricing in tax planning]

The book may draw interest of practitioners employed at companies that operate in any industry and carry out transactions with domestic of foreign related parties.

It provides the information indispensable to prepare detailed tax documentation of transactions between related parties, points to tax optimisation opportunities and draws on numerous examples, presents procedures as well as pieces of sample tax documentation.

Table of content:
1. Introduction

2. The essence of transfer pricing

3. Normative regulation of the transfer pricing concept

4. Determining the arm’s length value of the transaction object

5. Determining the tax obligation

6. Documenting selected types of transactions

7. Legal regulations

Legal status as at March 2005

Author: Dr. Marcin Jamroży, Tax Adviser
Publisher: Verlag Dashöfer
Format: A5
Number of pages: 168
ISBN: 83-88285-53-X
Price: PLN 89,00
Orders: Dashofer