The interpretative practice mitigates the entry conditions for multilevel structures. It is worth pointing out that the KIS interpretation of October , no. KDIP MW confirm the right to Estonian CIT of the entity that is a party to the civil partnership agreement notes Bartosz Przybysz. Read also A silent partnership between spouses Another expert also positively assesses the interpretation. The tax authority present an interpretation of the provisions of the tax law regarding lumpsum taxation on the income of companies, using a linguistic interpretation of the provision on the conditions to be met by the entity.
This interpretation is absolutely
Correct when applying the linguistic interpretation of the provision in question the applicant, being a party to the silent partnership agreement, has the right to choose the Estonian CIT assesses Stefan Kowalski, legal advisor, partner at Kowalski Wisła Attorneys. However, the expert advises taxpayers to be careful Despite the fact that the authority South Korea Phone Numbers List present the reasons for the linguistic interpretation its priority over the systemic teleological interpretation, to other taxpayers who are partners in a silent partnership want to opt for lumpsum taxation on the income of companies, I would recommend a great deal of caution requesting an individual interpretation from the director of KIS yes in order to obtain the protection provid for in the tax ordinance advises Stefan Kowalski.
In his opinion this caution
Results from the lack of protection of compliance with an interpretation not issu in his own case the justification for the act introducing lumpsum taxation on the income of companies The introduc conditions regarding employment the structure UK Email Database of income are intend to limit the possibility of using this tax option to those entities that do not conduct actual business activity The purpose of introducing this condition is to limit the possibility of using flatrate taxation by entities not conducting active economic activity, but focus on deriving revenues mainly from passive sources of revenue. Such information is contain in print no indicates Stefan Kowalski.