Amendments to the Polish Pillar Two (BEPS 2.0.) Act. What taxpayers need to know?
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On behalf of the AmCham Tax & Financial Services Committee, we invite you to a meeting entitled Amendments to the Polish Pillar Two (BEPS 2.0.) Act. What taxpayers need to know?
One of the key assumptions of Pillar 2 is a common approach. This means that countries that have decided to adopt the principles of Pillar 2 are obligated to implement and interpret the regulations in accordance with the OECD Implementation Framework. The amendment aims to incorporate the OECD Administrative Guidances from June 2024 and January 2025 into the Polish legal system. In addition, the amendment seeks to clarify national regulations that raise interpretative doubts among taxpayers.
Our speakers will be from EY Poland International Tax and Transaction Services team, Michał Koper, Partner; Filip Majdowski, PhD, Director; and Arkadiusz Myszkowski, Senior, and we will discuss:
- requirements regarding the accounting standard used for calculating Qualifying Domestic-Minimum Top-Up Tax (QDMTT), in particular local GAAP vs. IFRS;
- changes regarding the application of the Transitional CbCR Safe Harbor;
- the scope of required changes resulting from the implementation of the OECD Administrative Guidance from June 2024, among others, in the area of differences between values for the purposes of the Pillar 2 system and accounting values, clarification of the rules regarding the allocation of taxes from the headquarters to the permanent establishment, as well as clarification regarding substitute assets related to tax incentives;
- the scope of required changes resulting from the implementation of the OECD Administrative Guidance from January 2025 in the area of clarification of the rules for recognizing deferred tax assets (DTAs) arising from tax incentives.
The meeting will take place on Wednesday, March 25, from 9:30 a.m. to 11:00 a.m. We encourage you to visit the AmCham office, Spektrum, ul. Twarda 18, 16th floor (live tickets are limited to 25 people; for those registering live, please click the live ticket). The Webex link will be sent to all online attendees one day before the event.
SPEAKERS
Michal Koper
Filip Majdowski
Arkadiusz Myszkowski