Klauzula przeciwko unikaniu opodatkowania jako norma znajdująca do 31 grudnia 2018 r. zastosowanie ex lege
Polish GAAR as regulation applicable to 31 December 2018 ex lege

Summary/Abstract: The article dicusses whether polish general anti-avoidance regulations (GAAR), in the wording applicable to 31 December 2018 r., were supposed to be applied by a taxpayer during calculation of due tax or was is only the tax authorities that were authorized to apply GAAR during a tax proceeding. The author claims that the GAAR was applicable ex lege. He critize amendments to the tax ordinance introduces as of 1 January 2019 leading to discretionary power of the tax authorities to apply GAAR.

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