Substance
Support of the Opus Group in the context of changes in regulations regarding controlled foreign companies (CFC)
In connection with the amendment of regulations regarding controlled foreign companies (CFC), the Opus Group is implementing comprehensive solutions that allow for the creation or adjustment of existing structures to ensure they remain tax-optimal. The changes result from the Act amending the Corporate Income Tax Act, the Personal Income Tax Act, and certain other acts, which introduces the taxation of CFC income into the Polish legal system.
Actual economic activity as the key to compliance
The new regulations place particular emphasis on conducting actual economic activity (so-called substance) by controlled foreign companies. To meet these requirements, OpusTax specialists have developed a dedicated audit program for international structures regarding their compliance with CFC rules.
The scope of the audit service includes:
A comprehensive analysis of the factual state – a thorough examination of the company’s operations and legal environment.
An assessment of the risk of inclusion under CFC rules – determining whether a particular company or structure is subject to regulations arising from the amendment of the law.
An audit allows for the determination of whether the available tools and mechanisms are sufficient to demonstrate that the company conducts genuine economic activity in accordance with the new requirements.
Any questions?
We encourage you to get in touch.
Support
Further support in case of CFC risk identification
In a situation where the audit result indicates the risk of taxation on CFC income, the Opus Group recommends using the services of our Partner – the American company Business Setting Services (BSS).
The range of BSS services includes:
Support for entrepreneurs' expansion into new markets
Help in establishing a business in key locations in Europe and the USA
Human Resource Management and Office Logistics
Solutions that promote the strengthening of actual business activity, which translates into the company's recognition as a tax resident in a given country
Thanks to the collaboration with BSS, entrepreneurs can effectively adjust their structures to legal and tax requirements, while also increasing their competitiveness in the international market.
Benefits
Benefits of implementing an audit and services of the Opus Group
Adjusting structures to new regulations allows not only for reducing the risks associated with CFC income taxation but also for increasing transparency and stability in business operations. The Opus Group offers full support in the auditing process, as well as advice on creating effective tax structures. We invite you to contact us to discuss your needs and the support opportunities within our offering.
Contact
Contact us
Headquarters
Warszawa
Opus Group Office in Warsaw
al. J.Ch. Szucha 8
00-582 Warsaw, Poland
Phone (+48) 22 201 08 10
Mobile (+48) 503 306 924
