Poland proposes change to shifted profits tax that places burden of proof on the Polish taxpayer

At the end of August, the Polish Government submitted to Parliament draft legislation implementing changes to the Corporate Income Tax Law. On 19 September 2022, the draft bill was passed to the Upper Chamber of the Polish Parliament with some additional modifications.

The amendments also include additional modifications to the shifted profit tax regulations. This Alert outlines the key proposed change regarding shifting the burden of proof to the Polish taxpayer. It also outlines the overall pro…