Cross-Border Conversions and Global Tax Reform: A New Landscape for Business Expansion in Poland
The new regulations may significantly benefit companies planning to start operations in Poland, transfer part of their business to a Polish company (or conduct the reverse transaction), or increase the autonomy of their foreign branches.These changes to Polish law are part of the implementation of the EU Directive (EU) 2019/2121 of the European Parliament and of the Council of 27 November 2019 amending Directive (EU) 2017/1132 as regards cross-border conversions, mergers, and divisions (“Directive”).
The primary aim of this Directive is to harmonize the laws of Member States concerning cross-border reorganization processes. Most EU Member States have already completed the implementation of the Directive, allowing cross-border procedures to be carried out on a larger scale, involving companies from different Member States
.At the same time, significant global tax reforms are underway, which will undoubtedly impact the tax burdens of multinational corporate groups. This refers to initiatives related to Pillar One and Pillar Two – the two core components of the project to reform corporate income tax rules developed by the Organization for Economic Cooperation and Development (OECD). It is also important to consider the EU tax law changes under the so-called ATAD III Directive.
These reforms will result in new and substantial tax burdens for many corporate groups, potentially necessitating an optimization of their structures.The legal tools implemented across the Member States to enable cross-border conversions, mergers, and divisions offer companies improved conditions for international expansion and business growth. Now is an ideal time to seize these new opportunities and align your business structure with the evolving landscape.
Download: Cross-border divisions in Poland – a guide to cross-border divisions involving Polish entities
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