Poland: Clearance opinion approving group restructuring

National Revenue Administration determined that tax benefit not the main, or one of the main purposes, of restructuring

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April 30, 2025

The Head of the National Revenue Administration (NRA) on March 11, 2025, issued a clearance opinion (DKP16.8082.9.2024) approving a group restructuring consisting of a share exchange followed by a cross-border merger.

The NRA acknowledged that the transaction was structured to qualify for exemption from the tax on civil law transactions and be corporate income tax neutral, but determined that a tax benefit was not the main, or one of the main purposes, of the transaction. Rather, the primary goal of the transaction was to streamline the group’s corporate structure in order to reduce administrative complexity and enhance operational control. The NRA also examined an alternative approach of achieving the same structure and found that this option would have led to higher costs and resulted in a misalignment with strategic business goals.

Read an April 2025 report prepared by the KPMG’s EU Tax Centre

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