From 2024, the Member States of the European Union (EU) will be required to apply legislation implementing Council Directive (EU) 2022/2523 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union (the so-called Pillar 2 Directive).

The Pillar 2 Directive concerns a minimum tax, also known as a top-up tax, imposed on large groups in accordance with the relevant OECD rules to ensure that their effective tax rate is at least 15% in each country they operate in.

Poland has not yet transposed the Pillar 2 Directive, but in April this year a long-awaited bill on the top-up taxation of entities forming international and domestic groups appeared, which envisages the introduction of relevant solutions into Polish law. The bill is currently under consultation. The law is expected to enter into force on 1 January 2025.

Please join us for a webinar on the upcoming changes, where we will discuss:

• the scope of companies covered by the new top-up tax rules,
• the main principles of application of the top-up tax rules and their impact on the tax exposure of the group,
• the practical impact of the top-up tax on the operations of taxpayers using or considering tax incentives for investment or innovation, including the tax exemption in the Polish Investment Zone, R&D relief or other similar instruments,
• possibilities of mitigating financial liabilities related to the top-up tax, including on the basis of the so-called substance carve-out and other mechanisms to eliminate or mitigate the burden of the top-up tax,
• new obligations, deadlines and risks for Polish companies and their management and financial services.

Is the event for you?

The event is for people interested in and dealing with tax issues on a daily basis, especially business owners, business managers, directors and employees of financial, legal and tax departments.

Organisational information:

• Participation in the webinar is free of charge, but registration is required.
• The event will be conducted in English.
• The organizer reserves the right to select applications.
• Attendance translates into training points required for continuing education obligations.
• For questions about the event, please contact Iryna Svitelska, marketing & BD manager: iryna.svitelska@dentons.com