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Such action is not reasonable rational

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發表於 2023-11-26 18:32:57 | 顯示全部樓層 |閱讀模式
Adres email  Akceptuję regulamin i zapisuję się do newslettera zawierającego informacje o produktach i usługach .  Zapisz się Clause against tax avoidance However, before we move on to the protective opinion, it is necessary to outline what an anti-tax avoidance clause is. An anti-tax avoidance clause is a decision issued by the National Tax Administration KAS stating that an entrepreneur is intentionally avoiding taxation. It applies to an activity performed mainly for the purpose of obtaining a tax benefit or when one of the main goals was to obtain such a benefit.

If this benefit is contrary to the object or purpose of the tax act or its provisions. That is, when certain activities are performed artificially, only to obtain a tax benefit avoid taxation, and if it were not for this benefit, the entrepreneur would not undertake such activities, because from the business point of view, and would not is photo editing servies economically justified. When assessing whether the method of operation was artificial, the head of the National.



Justification, elements leading to achieving a state identical or similar to the state existing before the action was performed, elements that cancel or compensate each other, economic risk that exceeds the expected non-tax benefits to such an extent that it should be considered that a reasonable entity would not choose this course of action. [size=14.6667px]Tax Administration takes into account, among others: unjustified division of operations, engaging intermediary entities despite the lack of economic or economic.


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