On Friday, 24 August 2018, the Ministry of Finance ("MF") published extensive draft amendments to the Corporate Income Tax Act, Personal Income Tax Act and Tax Ordinance Act. New regulations are expected to enter into force at the beginning of 2019.
The proposed provisions may have a significant impact on conducting business activity in Poland. Below please find the outline of the most important changes proposed by MF.
The proposed change means that unrealized capital gains related to the transfer of assets / tax residence / permanent establishment by the taxpayer outside the territory of Poland will be subject to a new tax.
The taxable amount is supposed to be the total income related to unrealized gains determined for particular assets. Income is going to be the surplus of the market value of the transferred assets, in particular arising from the change of the tax residence, over their tax value (determined as of the transfer date).
The tax rate applicable to CIT taxpayers is going to be 19% and the tax rates applicable to PIT taxpayers are going to be as follows: (i) 3% - if the tax value of the asset is not determined, and (ii) 19% - in other cases (also, PIT payers are exempt from tax in respect of assets valued at less than PLN 2 million).
Currently, passive income (e.g. interest, royalties) may be subject to a preferential rate or WHT exemption already at the moment of payment made by the Polish tax remitter provided that certain conditions are met.
The planned amendment will replace to some extent the tax relief available already at the moment of payment made by the tax remitter with the obligation of the Polish tax remitter to withhold tax at the standard rate (which subsequently may be reimbursed to a foreign taxpayer by the tax authorities).
The above change (applicable to payments in excess of PLN 2 million made to a particular recipient per year) is going to obligate the tax remitter to collect and pay WHT in the domestic rate (i.e. there will be no possibility to apply the reduced rate or WHT exemption) – subsequently a foreign taxpayer will be entitled to apply for WHT refund which will be granted only after positive verification by the tax authorities that all requirements have been met.
Please note that in specific cases the tax remitter will be allowed to apply the preferential tax treatment already at the moment of payment: (i) by submitting a statement to the tax authority (under pain of criminal fiscal liability) that it holds all documentation required to apply the reduced tax rate or WHT exemption or (ii) by obtaining a special opinion from the tax authority authorizing the tax remitter to apply a WHT exemption.
In addition, the draft amendments will also clarify the definition of "beneficial owner".
The planned changes may have a substantial impact on all passive income reconciliations.
According to the draft provisions, certain professional advisors indicated therein will be obliged for the first time to provide the tax authorities by the end of March 2019 with information on the tax schemes implemented by their clients (it also applies to schemes implemented in the period starting from 25 June to 31 December 2018). If an advisor pleads professional secrecy, the clients will be obliged to provide such information to the authorities by themselves. The draft bill provides for rigorous penal-fiscal sanctions for any non-compliance with the new requirements.
Apart from numerous provisions of rather clarifying nature (grounds for rejecting tax ruling motions, procedural changes, extension of GAAR also onto tax remitters) the draft bill introduces also an additional tax liability equal to 40% of the amount of the tax benefit achieved in a particular case subject to GAAR.
CFC is a term used in the context of regulations which provide for the obligation to include in the taxable amount at a resident taxpayer (a natural person and a corporate income tax payer) the income earned by a controlled foreign entity with a place of residence or management in a country with lower tax than the ones in force in the country of residence of such tax resident.
The draft bill provides for further changes aimed at increasing the effectiveness of CFC taxation, in particular by extending their application to foreign entities from outside of the Polish legal system – such as foreign foundations and trusts.
The proposed rate is going to apply to taxpayers whose revenue in a given tax year did not exceed an amount equivalent to EUR 1.2 million in relation to revenue (income) other than resulting from capital gains.
Hypothetical costs of obtaining external funds are going to be included in the tax deductible costs of the company if the company's sources of financing are additional payments made by shareholders and/or the so-called retained earnings (notional interest deduction - up to PLN 250,000 in a tax year).
According to the draft bill, the new regulations are going to allow for recognition of the full cost base of the purchase of receivables.
The draft bill provides for the WHT exemption of interest and discount, obtained by non-residents (both PIT and CIT taxpayers) on bonds issued and admitted to trading on a regulated market or introduced into an alternative trading system within the meaning of the Act of 29 July 2005 on trading in financial instruments that meet, inter alia, the condition of maturity, which should not be shorter than one year.
Please note that the above summary does not cover all of the changes included in the draft bill and is only a brief commentary on its most important elements (the draft bill contains more than 150 pages).
As a matter of principle, the changes are to apply to tax settlements starting from January 2019. However, the draft provisions may be subject to further changes during the legislative process.
If you would like to discuss the above-mentioned issues in more detail, please do not hesitate to contact us.


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Casey hails from Atlanta, GA, but has immersed himself in study and archaeological digs as often as possible in various sites within the middle East.
At CVV Bill would sometimes say that if you want to be a bridge you can expect to get stepped on from both sides. Nowhere have I seen this to be more accurate than in the Israeli/Palestinian conflict. Nearly two years ago after my year in Denver I moved to Israel to pursue an MA in archaeology at the University of Haifa near the Lebanon border. I started working on archaeological excavations in the ancient city of Ashkelon just north of the Gaza Strip in 2009, and I took a break from my formal academic studies to spend a year with CVV, where I had the opportunity to serve resettled refugees through Lutheran Family Services- a job that matched with my time abroad and fascination with other cultures. I traveled throughout Israel and Palestinian territories of the West Bank before I moved to my current apartment in Haifa, and I witnessed hints of violence or more often their awful effects, but it was not until the summer of 2014 that I truly experienced the climate of conflict when Hamas and the Israel Defense Forces exchanged rocket fire, airstrikes, and a small ground war. The only thing that the Israeli military and Hamas militants seemed to be able to agree about was the worthlessness of human life in the Gaza Strip. I was living in Jaffa south of Tel Aviv for the summer while I worked on an archaeological excavation, which ended early due to the conflict. The other staff and I had to run into the bomb shelters multiple times a day. You have about thirty seconds when you hear the siren. The Iron Dome system has neutralized much of the threat from rockets, but you may forget that when you do not make it to the shelter in time and you see an explosion a few hundred feet above your head, and the whole earth shakes.
Violence can be a kind of truth serum. Conversations and debates about the conflict are a common part of social life over here no matter where you live. However, it is not until a surge of violence that you see who people really are. Many of your Palestinian or Israeli friends whom you thought were fairly level headed and understanding will seem as if possessed. When the hatred and rage comes out it is like you are talking to another person. On the other hand, some friends you thought were strongly in favor of one side in heated debates may show a remarkable degree of compassion and level-headedness when bombs start to fly. There are three facts that Americans and Westerners in general need to understand about Israel/Palestine and the recent history of the Holy Land. First, whatever your opinion about who this land "belongs to," every group involved in this conflict has had children here. Your opinions about who came here at what time and formed a group identity and which is more or less legitimate do not matter. At this point generations on every side have been born here and grew up on this land with their respective identities, and this land is their home. Period. Second, people are not transient here the way we are in the USA. If the economy plummeted or violence and crime increased wherever you live in America you would probably move. We have hometowns and home states, but overall Americans regularly move, sometimes across great distances. That is not the case here in Israel/Palestine. It does not matter how dangerous a place becomes, how much you may lack basic necessities, or how difficult it becomes to live in your home because of the political situation. You hold on to your land until the bitter end no matter what. If you are forced out of it you fight to get it back, and if you do not win then your children or grandchildren continue the fight. Oftentimes the door is open to leave but not to return. This relates to the third point that Americans need to understand- this conflict is not about religion. It is about competing national identities. I do not just mean one against the other. Every side is prone to horrific infighting. Israelis have murdered Israelis, and Palestinians have murdered Palestinians over this conflict. "Israel" and "Palestine" are not set sides in the conflict. They are more like genres of sides. Being pro-either can mean a million things. These days when someone tells me he is "pro-Israel" or "pro-Palestine" I have to ask what he actually means by that statement because- contrary to the American media- the bare statement of that position tells you almost nothing about someone's views. Returning to the subject of religion, it is true that there is religious motivation for some groups like religious Israeli settlers or Jihadi groups among Palestinians, but oftentimes the rhetoric of religion is simply fodder for speeches. It is just how people talk over here. Some of the most hateful and violent people you may encounter in the Holy Land are completely secular.
Some of you reading this probably have very strong opinions about the conflict. You may be thinking, "Will Casey say something in favor of or against Israel or Palestine? Can he tell me where to put the blame for all this blood?" I could do that about every side in this conflict and their various factions (I could write a few volumes and maybe one day I will). However, I want to focus on what it means to try and be a bridge in this environment of seemingly endless conflict. Before you visit the Holy Land you probably have some opinions, but at the end of the day you think all the violence is senseless and simply needs to end. Then you come to the Holy Land, and travel, and your views become more nuanced. You see some of the worst hatred you will ever see. A Palestinian in a UNRWA refugee town will tell you Israelis are not human beings, and another will try to tell you about a conspiracy between the Freemasons and Jews to create a Zionist state, and then a right wing Israeli in a West Bank settlement will tell you that Palestinians are all barbaric terrorists, and you might see "Death to Arabs" spray painted on a wall in Jerusalem. However, amidst this hatred you will see profound love- made all the more powerful by the venom that surrounds it. You meet mothers who lost children on both sides coming together in their grief. An East Jerusalem Palestinian man from the Silwan neighborhood helps an Orthodox Jewish family stranded in the rare winter snowstorm. An Israeli friend of mine founded a program called "Skype With Your Enemy." While the rockets and airstrikes were flying over the summer she set up Skype conversations between Israelis and Palestinians in Gaza. The conversations were largely spoken in tears as each realized the humanity of the other face to face- even if on a laptop. You have to start somewhere.
If you want to be a bridge you need two main qualities: a thick skin and detachment from reward or results. People who really work for peace here can get murdered for it. The assassination of the pro-peace Israeli Prime Minister Yitzhak Rabin proved this. If you think it is dangerous to go to war then try going to peace. The story of Christ reminds us what can happen to the true peacemaker, and the last millennium has seen many martyrs like Rabin from Ghandi to Martin Luther King. Remember that even Malcolm X was not assassinated for all the hatred and anger in his earlier career. He was assassinated after his religious pilgrimage to Mecca transformed his views, and he began to talk about peace and understanding between blacks and whites. Thank God martyrdom is the rare and worst-case scenario for any public peacemakers. More often than not they are simply insulted. I have been involved with some groups that promote peace here, and some friends and I even founded a small non-profit to bring young Israelis and Palestinians to work with one another on archaeological excavations in the summer (If you want to donate then please visit www.archshare.org). Our organization has no political or religious affiliation, but in some conversations or debates about my work with conflict I have been called a colonialist Zionist occupier and an anti-Zionist anti-Semite: once in the same day. Just two days ago I was called a Holocaust denier… by a Palestinian from Hebron. That one came out of nowhere. When you are accused by insults that are polar opposites it usually means that you are exactly where you want to be. One of the dirtiest words over here is "normalization"- making the current status quo agreeable. It is a common insult thrown at any group promoting dialogue, as if the current situation is not exactly what we stand against. It is worthless to get mad at the people who insult you. Everyone here has lost someone in the conflict, and every group carries the sense that the rest of the world wants to destroy them. Emotions are very high. Simply forgive them when they insult you.
The second quality you need is detachment from any sense of reward. You may work your entire life for peace in this region and see all of your efforts crumble. Work for peace anyway. As Christians we are called to work for peace and have compassion on every person made in the image of God. Do what you can with what you have in this conflict, and the rest is up to the Lord. The Israeli/Palestinian conflict has only become worse over the past 20 years. Personally, I see it degrading at a faster rate every year. The peaks in violence run on a two year cycle that is horribly reliable, but I fear that we are reaching a breaking point in Israel/Palestine that will make all the blood of last summer look like nothing. It may not be long before it begins. You feel it growing beneath the surface in Jerusalem or speaking to Palestinians in the West Bank with an ever-increasing desperation in their voices. I hope and pray to God that I am wrong. Still, even if it all collapses into Hell and chaos- keep working for peace. Keep loving. Keep listening, and while you work for peace do not arrogantly claim to have all the answers. There are enough white Western activists with a misguided savior complex on every side over here. Ultimately, this conflict is for the people of this land to figure out, and no Westerner or foreign nation will fix this. We can promote peace or war and provide venues for meaningful dialogue, but we cannot determine the winner nor create a lasting peace from the outside.
Perhaps the Holy Land is a kind of test for Humanity. Three continents meet in this small country, and hundreds of cultures have encountered one another here for thousands of years- for better or worse. Many do not know that Armageddon is a real place. The Greek term comes from "Har Megiddo," which is an actual archaeological mound or "tel" of the kind we have everywhere in this cradle of civilization. At Megiddo archaeologists have uncovered twenty-six layers of destroyed cities- one on top of the other. This ancient city sits at a bottleneck in the Jezreel Valley, which is the only viable land route for any army passing through this region. If you controlled Megiddo then you controlled the land route between Africa, Europe, and Asia. The Book of Revelation uses imagery that readers in the late 1st or 2nd century would have understood. If you want to describe a battle to end all battles then everyone knew where it would be. How do we even talk about peace in a land with such a history of violence? Christians sometimes wonder why God would choose to incarnate Himself in this particular place during a period of profound social instability. Perhaps our "Prince of Peace" came to this land because peace appears impossible here. Our faith in God, our faith in humanity, and our love for our enemies are pushed to their limits in the Holy Land. We keep building walls and buying weapons to create a false peace based on "security," but God reminds us of another way. He sends prophets and saints to remind us, but we throw them in prison or murder them. Still, God loves us and does not give up on us or on this place. We are called to have the same perseverance as Christ whether we are talking about the conflict in Israel/Palestine, some other part of the world, or even the conflict within ourselves. A bridge offers a path, but no one is forced to cross it. The bridge is merely an invitation to something better. Be the bridge in the conflicts you know and especially in those places where the river is widest. When a bridge collapses another will be built, and even if a bridge is not rebuilt we should remember that Jesus walks on water.


One-third of the flights at Denver International Airport have been cancelled.
Here is the winter weather warning map.
The orange areas are blizzard warnings. The light green is a blizzard watch. Pink is a winter storm warning. The magenta and brown areas in Texas and southeast New Mexico are high wind/wildfire danger warnings.
This is the last update on the blizzard. I will have coverage tomorrow morning of the tornado/severe thunderstorm threat for tomorrow afternoon and night in the South and Ohio Valley.


Friday again?! Where does the week go?? I managed to squeak in another Friday Foodle for you guys. Nikki has been requesting this tasty treat over on my Facebook Page ever since I started asking for suggestions, so I decided it was time to make her dreams come true!
Actually, Dragonfruit, also known as Pitaya, really reminds me of Kiwi in texture. Which is a coincidence because that's what I drew last week! This is actually the third Dragonfruit I've drawn. The first was for my Dragon Eye Salad, and the second had a smiley face on it! Yum! Enjoy and have a great weekend!