Abstract

Holding structures that benefit from tax preferences are popular in many tax jurisdictions - such a solution has also been introduced into Polish tax regulations. A Polish holding company is an institution that is supposed to provide incentives to capital groups for further investment in exchange for preferential taxation of transactions of share deal against payment to non-related parties and exemption from taxation of dividends paid out.

Taking advantage of the preferences is possible with respect to income earned after 1/01/2022. Entities intending to take advantage of the tax preferences provided for a holding company must meet the conditions specified in Corporate Income Tax Act, the interpretation of which raises many doubts among taxpayers.