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Poland: Tax disputes on credit guarantees at no charge finally solved

01 July 2012



Igor Fudali
Tomasz Adamski
Credit securities are recently among the tax issues of special interest in Poland. Disputes arose on whether guarantee provided at no charge or for the fee lower than on the market constitutes taxable revenue for the entity that receives such credit collateral. The point of these arguments was whether credit guarantee is a service that should be remunerated at the moment it is issued or only in case the debtor fails to pay secured liabilities. The issue was particularly important for multinationals that widely use intra group guarantees to support financing of their subsidiaries.

When should intra-group credit guarantee be remunerated? The answer to...



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