Council: the general clause can be applied retroactively. Experts: this is a mistake
At the end of last year, at the request of the Head of the National Tax Administration, the Council for the Prevention of Tax Avoidance issued three precedent opinions on the application of the general clause against tax avoidance. The most interesting thing about them is a statement that the clause can be used when all activities were carried out by the taxpayer before it entered into force. According to experts, the opinion of the Council is incorrect.
Andrzej Ladziński's commentary can be found in today's issue of Dziennik Gazeta Prawna.
https://gospodarka.dziennik.pl/news/artykuly/6420528,eksperci-fiskus-podatki.html
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