Spółka osobowa za granicą – skutki podatkowe

Szef Krajowej Informacji Skarbowej umieścił na swojej stronie kolejne ostrzeżenie skierowane do podatników. Tym razem zwraca uwagę na skutki utworzenia spółki osobowej poza Polską (np. spółki komandytowej) w sytuacji, gdy faktyczna działalność prowadzona jest z Polski, a spółka nie dysponuje zasobami finansowymi, organizacyjnymi i kadrowymi do świadczenia usług.

Jest to od kilku miesięcy stosowana strategia na zmniejszenie obciążeń podatkowych w Polsce.

Szef KAS zwraca uwagę na wnioski o wydanie indywidualnej interpretacji prawa podatkowego kierowane przez podatników podatku dochodowego od osób fizycznych, w których przedstawiany jest stan faktyczny, dotyczący posiadania zagranicznego zakładu w formie spółki osobowej, wskazujący w opinii Szefa KAS na możliwość zastosowania przepisów o przeciwdziałaniu unikaniu opodatkowania.

Opisywany przez wnioskodawców zespół czynności polega na zaistnieniu następujących elementów:

1. osoba fizyczna, będąca polskim rezydentem podatkowym (np. prowadząca działalność w zakresie świadczenia usług niematerialnych) przystępuje, jako wspólnik ponoszący ograniczoną odpowiedzialność, do spółki nieposiadającej osobowości prawnej (spółka osobowa) mającej siedzibę za granicą, której struktura odpowiada formie prawnej spółki komandytowej,

2. uczestnictwo w spółce osobowej, która nie jest podatnikiem podatku dochodowego w kraju siedziby, skutkuje powstaniem zagranicznego zakładu osoby fizycznej zgodnie z postanowieniami umów o unikanie podwójnego opodatkowania,

3. zagraniczna spółka osobowa prowadzi działalność gospodarczą, polegającą na świadczeniu analogicznych usług niematerialnych, w szczególności na rzecz podmiotów polskich,

4. wynagrodzenie zagranicznej spółki osobowej poddawane jest opodatkowaniu w państwie, w którym została utworzona, na zasadzie osiągania dochodów z działalności gospodarczej za pośrednictwem zakładu w tym państwie [patrz odpowiednio art. 7 umów o unikaniu podwójnego opodatkowania]. Z reguły stawka podatku dochodowego w tym państwie jest znacząco niższa niż stawka obowiązująca w Polsce, lub występują wysokie kwoty wolne od podatku.

Jeśli w wyniku przeprowadzonej kontroli organ podatkowy stwierdzi, że zagraniczna spółka osobowa, w której wspólnikiem jest osoba fizyczna, będąca polskim rezydentem podatkowym (Polak mieszający w Polsce lub posiadający w Polsce rodzinę), nie posiadała substratu materialnego na terenie państwa swojej rejestracji, który uprawniał do zastosowania regulacji prawnych dotyczących zagranicznego zakładu, ani tym bardziej nie świadczyła fizycznie usług z terytorium tego państwa, cała struktura zostanie uznana za działanie zmierzające do unikania opodatkowania. W konsekwencji dochód wygenerowany przez spółkę osobową może podlegać opodatkowaniu zarówno za granicą – w miejscu położenia zakładu, jak i w Polsce – na podstawie 119a Ordynacji podatkowej – klauzula unikania opodatkowania.

Autor: Aneta Dobczyńska
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W celu uzyskania bliższych informacji odnośnie wyżej poruszonego zagadnienia lub naszej oferty prosimy o kontakt na adres: biuro@meritor.pl lub kom. +48 602 193 716 lub poprzez formularz kontaktowy na naszej stornie internetowej.

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