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X-ORIGINAL-URL:https://dev2.bpcc.org.pl/
X-WR-CALNAME:British Polish Chamber of Commerce
X-WR-CALDESC:BPCC
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BEGIN:VEVENT
CLASS:PUBLIC
UID:MEC-e1166024037608746496d53e2d03f97f@dev2.bpcc.org.pl
DTSTART:20231123T090000Z
DTEND:20231123T103000Z
DTSTAMP:20231106T111600Z
CREATED:20231106
LAST-MODIFIED:20231106
PRIORITY:5
SEQUENCE:3
TRANSP:OPAQUE
SUMMARY:Webinar I WHT and ATAD II (hybrid mismatches) practice in Poland and the Netherlands
DESCRIPTION:WHT is one of the hot tax topics in last years in Poland. Both the provisions and practice become stricter and vaguer. Polish Ministry of Finance guidelines only intensified these issues. In our webinar we will discuss available options for tax remitters and taxpayers to navigate through such WHT landscape.  In this context, it is among other things of key importance how the recipient of the income has organized its business organisation in its jurisdiction of residence (e.g., the Netherlands) in terms of the level of substance and beneficial ownership.\nATAD II provisions (prevention of hybrid mismatches) hasn’t reached first pages of tax newspapers yet, but nevertheless they concern considerable portion of taxpayers. It may significantly affect tax position of companies from international groups who have entities from the US (due to their check-the-box election mechanism) and tax havens. ATAD II provisions may also pose tax obligations on entities who do not have knowledge or do not engage directly in hybrid transactions, if the hybrid mismatch arises at the subsequent steps of the structure or transaction. It should therefore be ensured that the potential implications of ATAD II are reviewed taking into account the entire (financing) structure.\nIn this respect we would like to invite you on next webinar organized jointly by MDDP and Loyens Loeff.\nThe webinar will be conducted in English and is free of charge.\nAgenda\nDuring the webinar, among others, the following points shall be discussed:\nATAD II (hybrid mismatches) – 45 min total\n\nGeneral rules\nDouble deduction – Case Study 1: Check the box mechanism/ qualification of permanent establishments\nDeduction without inclusion – Case Study 2: Financing from shareholder from the US\nImported hybrid mismatches –\nCase Study 3: Financing from the Netherlands\n\nWHT – 45 min total\n\nWHT rules\nGuidelines, case law and its application\nFuture outlook\nConducting actual economic activity (substance)\nBeneficial owner status requirements (other than substance)\nPossibility of look-through approach\nManaging WHT position\n\nImproving beneficial owner status\nInsurance possibilities\nOther payment titles\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n
URL:https://dev2.bpcc.org.pl/events/webinar-i-wht-and-atad-ii-hybrid-mismatches-practice-in-poland-and-the-netherlands/
ORGANIZER;CN=MDDP:MAILTO:
CATEGORIES:Tax & finance
LOCATION:Online
ATTACH;FMTTYPE=image/png:https://dev2.bpcc.org.pl/wp-content/uploads/2023/09/sub_tax-finance_9f917f.png
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