Ochrona adresata interpretacji indywidualnej nieuwzględniającej stanowiska wnioskodawcy
PROTECTION OF THE HOLDER OF A TAX RULING WHERE THE TAX RULING DOES NOT CONFIRM THE HOLDER’S POSITIONS
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In Poland taxable persons may apply for tax rulings whenever they have doubts concerning tax provisions that are – or potentially can be – applicable to them. In an application for a tax ruling a taxable person is required to present his, her or its own position concerning the interpretation of tax law provision in question. If a tax authority issuing a tax ruling agrees with the applicant, the ruling merely states that the applicant’s position is correct. If this is not the case, the tax authority presents its own position on the interpretation of the regulation in question. The author argues that the scope of protection of the holder of a tax ruling is the same, whether the ruling confirms the applicant’s position or not.
Publication order reference