The Polish Investment Zone (PIZ) is an instrument that has revolutionized the investment incentive system, transferring tax preferences from the former special economic zones to the entire country. BTTP's substantive support in this area is dedicated to companies planning expansion, the construction of new plants, or fundamental changes to their production processes. The foundation of this service is obtaining a Support Decision, which entitles them to a CIT or PIT exemption. However, this process requires meeting numerous quantitative criteria (investment expenditures dependent on the regional unemployment rate) and qualitative criteria promoting innovation, environmental protection, and human resources development. At BTTP, we place particular emphasis on the correct definition of "new investment." We assist in precisely formulating the support application, ensuring consistency between PKWiU/PKD codes and the planned activity generating exempt income. However, our work does not end with obtaining the decision. The greatest substantive challenge arises during the operational phase. As a rule, income from a supported investment must be strictly separated from income from other activities. As specialists combining taxation with accounting, we implement precise cost and revenue analytics in our clients' companies. We use allocation keys for general and administrative expenses and verify eligible costs (capital expenditures or two-year labor costs). We monitor public aid limits, taking into account discounting and cumulation with other forms of support. A key element of our service is also protection against the risk of exemptions being challenged during audits. We prepare documentation confirming the implementation of declared quality criteria and ensure that tax savings resulting from PSI can be safely reinvested.
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Paweł Turek
Partner, Attorney-at-law, Tax Advisor
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Krzysztof Burzynski
Partner, Tax Advisor
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Grzegorz Podgorski
Partner, Attorney-at-law, Tax Advisor