Post by account_disabled on Dec 2, 2023 8:00:46 GMT 1
Taking into account the facts presented and the legal provisions referred to above it should be stated that the loan agreement was not subject to tax on civil law transactions pursuant to Art. section point of the Act on Tax on Civil Law Transactions because - as indicated in the application - the funds being the subject of the loan agreement were located outside the territory of the Republic of Poland at the time of its conclusion and the loan agreement was concluded outside the territory of the Republic of Poland. Individual interpretation of the Director of KIS of April.
ASZ the described loan agreement is not subject to tax on civil law transactions pursuant to Art. section of the Act on Tax on Civil Law Transactions because as the Applicant indicated the funds that are the subject of the loan agreement at the time of its conclusion photo editing servies will be located outside the territory of the Republic of Poland and the loan agreement will be concluded outside. A similar position was taken by the Supreme Administrative Court in its judgment of November act II FSK indicating that.
In relation to a money loan agreement the criterion of the location of the thing cannot be in the light of the wording of Art. section of the Act of September on tax on civil law transactions consolidated text Journal of Laws of item as amended decisive for the establishment of tax liability. This role is played by the place of execution of the property rights arising from the loan agreement. The exercise of the property right referred to above constitutes the delivery of money to the borrower. If it took place in the territory of another country then the loan agreement is not subject to pursuant to Art.
ASZ the described loan agreement is not subject to tax on civil law transactions pursuant to Art. section of the Act on Tax on Civil Law Transactions because as the Applicant indicated the funds that are the subject of the loan agreement at the time of its conclusion photo editing servies will be located outside the territory of the Republic of Poland and the loan agreement will be concluded outside. A similar position was taken by the Supreme Administrative Court in its judgment of November act II FSK indicating that.
In relation to a money loan agreement the criterion of the location of the thing cannot be in the light of the wording of Art. section of the Act of September on tax on civil law transactions consolidated text Journal of Laws of item as amended decisive for the establishment of tax liability. This role is played by the place of execution of the property rights arising from the loan agreement. The exercise of the property right referred to above constitutes the delivery of money to the borrower. If it took place in the territory of another country then the loan agreement is not subject to pursuant to Art.