Introduction of exit tax to the Polish tax system results from an obligation to implement the Directive (UE) 2016/1164, adopted in 2016. The mentioned directive establishes provisions in order to prevent tax avoidance practices, which may have indirect impact to functioning of the internal market, so called the ATAD Directive.
A crucial assumption of the exit tax is taxation of unrealized profits in connection with moving one’s assets to another country, also those which are part of a permanent establishment.
The tax is also due in case of change of the residency status of a taxpayer, which deprives Poland from taxation of income from sale of the individual’s assets. This is not required by the ATAD Directive – the Polish law in this issue goes beyond the requirements of the ATAD Directive and implements taxation of natural persons, who change their residency.
In accordance with the provisions introduced as of …
