ity between book valuation and tax reporting is required .
Capital gains / There is no separate capital gains tax . Capital gains or losses are aggregated with the entity's other taxable income or losses . Capital losses are tax deductible .
Intercompany dividends / Dividends received from Polish subsidiaries and other domestic corporations within Poland are not included in the taxable income of the recipient but are subject to withholding taxes ( see “Withholding taxes ” below ).
Foreign income/Resident corporations are taxed on their worldwide income unless an agreement between the Republic of Poland and the foreign state stipulates otherwise.
stock dividends /The payment of stock dividends is treated as a
distribution of dividends , which means that they are not included in taxable income of the recipient but are subject to withholding taxes ( see “ Withholding taxes ” below ).
DEDUCTIONS
Depreciation and depletion/ Depreciation is treated as a tax-allowable cost and can be calculated by using the straight-line method . Maximum straight-line rates are provided by Ministerial decree. However , for certain categories of plant and machinery and motor vehicles (not including passenger cars ) the reducing-balance method of depreciation may be applied so that depreciation can be charged at a higher rate .
These rates are computed by multiplying the standard rate by a maximum of 2 or , in the case of regions threatened by high structural unemployment , a maximum of 3. The basis of the calculation is the net value of fixed assets . The reducing-balance method is applied until the annual depreciation charge equals the depreciation charge that would have been produced under the straight-line method . In this way , during the initial period of using the fixed assets the owner receives
the benefit of accelerated depreciation . In 1994 and earlier years no depreciation for tax and for accounting
purposes . From 1995 the accounting regulations allow businesses to use more flexible depreciation rates for accounting purposes . However , this dose not apply to tax depreciation .
The main categories of assets and their statutory annual tax
depreciation rates are as follows .
Various buildings and constructions 1.5--10.0
Machinery and equipment general ) 5.0--20.0
Machinery for road building and construction 14.0--50.0
Machinery for paper industry 10.0--12.5
Various rail vehicles, ships and aircraft 6.0--20.0
Road transportation vehicles (except cars ) 12.5--20.0
Office equipment 12.5--14.0
Electronic measuring equipment for
Laboratories, computers 20.0--30.0
Accelerated depreciation ( within specified limits ) is also available for assets used in deteriorated conditions and for secondhand assets .
Net operating losses / The taxpayer has the fight to carry forward a loss incurred in a tax accounting period by deducting the loss from its taxable income over the following five years , with the possibility of the use of up to 50% of the loss in a given year.
payments to foreign affiliates/ Under current legislation, deductions can be claimed for royalties , management services and interest charges paid to foreign affiliates ( interest subject to thin-capitalization restrictions ),provided exchange control regulations and transfer pricing restrictions are observed .
Thin capitalization / As of January 1 ,1999 , thin-capitalization rules have been introduced . The provisions state that part of the interest paid by a Polish company on a loan issued by a qualifying shareholder will not be considered a cost of earning revenue ( i . e .nondeductible interest ) if the value of the Polish company's overall debt from the shareholders exceeds three times the value of the Polish company's share capital ( 3:1 debt-to-equity ratio ). A
qualifying shareholder is defined as a shareholder or group of
shareholders owning 25% or mor
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