Abstract

The lawmaker introduced new law regulations regarding “investment agreement” to the tax ordinance. The key reason for their introduction was the intent of the lawmaker to exercise the principle of certainty of tax law and guarantee its consistent interpretation, which is significantly crucial for protection of rights of taxpayers in Poland. Apart from investors interested in not violating tax obligations, the Minister of Finance plays an important role in execution of this procedure.

The analysis of new regulations allows to answer the question regarding mutual relations between investment agreements and individual interpretations of tax law regulations as well as tax agreements. A separate issue regulated in the new provisions is the admissibility to take over the rights coming from arrangements made by entities which develop due to a merger, division or transformation.