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Poland

Italy

IOTA Peer-to-Peer Technical Assistance Project “Advance Tax Ruling as a Tool for Supporting Tax Compliance in Investments”

Poland and Italy shared experience in the framework of IOTA Peer-to-Peer Technical Assistance Project “Advance Tax Ruling as a Tool for Supporting Tax Compliance in Investments”. The next IOTA Peer-to-Peer Technical Assistance Project was successfully implemented by the Italian Revenue Agency as the Provider and the National Revenue Administration under the Ministry of Finance of the Republic of Poland as the Beneficiary.

Italy and Poland have similar legal instruments allowing large investors to obtain advance tax rulings on their new investments as a preventive opinion from a tax administration about the tax treatment applicable to business plans and related extraordinary operations. Such instruments are intended both to guarantee to the investor the certainty in appraising the fiscal burdens connected to significant investments and to seek a uniform and consistent interpretation of tax legislation. Therefore the main goal of this technical assistance project was to increase tax compliance in Poland by improving the present instrument taking into account the best practices and lessons learned by the Italian Revenue Agency in this area.       

On 12 and 13 December 2023, the project teams had working meetings hosted by the Italian Revenue Agency in Rome, Italy. During the meetings, the Provider’s team shared many valuable insights, highlighting both specific solutions and a broad overview of legal and organisational arrangements for investment support in Italy.

More specifically, the discussions covered organisational and legal aspects of the procedure, including the coordination within tax administration, the scope of analysis of the investment, assessing the instrument's effectiveness, and providing open and trustful communication space between an applicant and tax administration. Provider’s good practices identified during the meetings included the importance of establishing a legal and procedural framework that ensures prompt and legitimate responses for investors, with clear statutory requirements for the decision-making process, building mutual trust between a taxpayer and a tax administration, consideration of investment’s positive revenue effect on the tax system and its significant, lasting positive employment effects, comprehensive nature of the instrument and other investment incentives.

The Parties agreed that the project was successful and that the obtained knowledge will help the Beneficiary to further enhance the Polish instrument aiming to ensure its maximum effectiveness and added value for the investment climate and the state budget.  

Find out more about the Project by visiting the dedicated Project page on the IOTA website.

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