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  1. 1 Kwartalnik Prawa Podatkowego

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  1. 1 Brzeziński B.

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  1. 1 2011

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Opłata dystrybucyjna w grupie spółek jako koszt uzyskania przychodów

100%
Brzeziński B.
Kwartalnik Prawa Podatkowego
|
2011
|
issue 4
101-106
EN
In contemporary economic practice there is a grooving number of international group of companies. Frequently in such a group one of companies acts as the management by proposing a strategy of the group and organizing cooperation between companies belonging to the group. Other companies, having often location in different countries, carry out specific functions, such as research and development, production, coordination and supervision of sales, marketing, logistics, management of intellectual property rights, etc. Such structures are usually completed by the local units which act as a local distributors of products, operating in predetermined local markets (distribution companies). The basis of the cooperation between the management company and distribution companies are often distribution agreements, giving rise to the principle of financial settlements between companies. In these settlements the main role plays a distribution fee. The distribution agreement is such that it admits the Polish company (the taxpayer) benefit as a percentage of the realized value of sales. If the economic results achieved in a given year exceeds the amount of benefits, the Polish company is obliged to make payment covering the difference between the indicated values, i.e. the distribution fee. If, however, the company has not reached in a given year fixed profit level, foreign management company will pay Polish company an amount representing compensation for the agreed but not achieved level of profit. The problem is qualification above mentioned distribution fee from the tax law point of view. The tax authorities consider that it does not fit in the category of deductible costs. This view is not suffciently substantiated. The article identified and analyzed a number of important arguments in favor of a different view.
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