Details about Tax startegy realised by Germania Mint Invest Sp. z o.o. for tax year 2021
Legal basis for preparing the information on the implemented tax strategy
Under Article 27c(1) of the Corporate Income Tax Act (hereinafter: CITA), a group of entities obliged to prepare and make publicly available information on the implemented tax strategy for a tax year has been specified. This provision refers to the entities indicated in Article 27b(2)(1) and (2) CITA, i.e. it lists:
tax capital groups, regardless of the amount of revenues achieved;
taxpayers other than tax capital groups whose revenue obtained in the tax year referred to in Article 27b(1) CITA exceeded the equivalent of EUR 50,000,000 converted into PLN at the average euro exchange rate announced by the National Bank of Poland on the last working day of the calendar year preceding the year in which the individual taxpayers’ data are made public.
Introduction
This information concerns the tax strategy implemented by the Company in the tax year from 1.01.2021 to 31.12.2021 and does not refer to information access to which is restricted due to applicable legal provisions, in particular information covered by regulations on the protection of classified information, information which the Company may not disclose due to obligations imposed on it under the law, contractual obligations or the Company’s business decisions. Additionally, this information does not include confidential information which, due to the Company’s plans and business undertakings, is protected as data covered by trade, industrial, professional secrecy or secrecy of the production process.
General information about the Taxpayer
Germania Mint Invest limited liability company with its registered office in Jelenia Góra, Aleja Wojska Polskiego 21, postal code 58-500, REGON: 022297193, NIP: 6112732869, entered in the register of entrepreneurs of the National Court Register kept by the District Court in Wrocław, 11th Commercial Division of the National Court Register under KRS number 0000486736.
Management Board of the Company: The one-person Management Board President is Szymon Kurowski.
Scope of the Company's business:
Wholesale of metals and metal ores
Manufacture of precious metals
Treatment of metals and coating of metals
Manufacture of coins
Casting of other non-ferrous metals, not elsewhere classified
Other service activities, not elsewhere classified
Information on the processes and procedures applied by the taxpayer regarding management of the performance of obligations arising from tax law and ensuring their proper performance
The tax strategy adopted by the Company is tailored to its size and structure and to the industry in which the Company operates. This strategy also supports the identification of potential tax risk by the finance and accounting function, facilitates the management of this risk and minimises the possibility of its materialisation. The Company’s tax strategy is intended to ensure:
support in the implementation of strategic business objectives;
taking responsible business decisions;
correct performance of reporting and filing obligations;
correct declaration and settlement of tax liabilities;
cooperation with the authorities of the National Revenue Administration within available mechanisms.
The Company’s Management Board ensures effective and adequate control of the organisation from the perspective of fulfilling obligations imposed on the Company by tax law provisions, in particular by:
exercising due diligence to ensure the correctness of the Company’s tax settlements;
demonstrating a proactive attitude in indicating values and building the organisational culture, including in the area of transparency of tax settlements;
placing emphasis on the verification of its contractors and business partners, in particular as regards their registered office and the business activity conducted;
taking decisions to limit tax risk by minimising threats from the external and internal environment.
The Company manages tax risk by identifying and continuously monitoring key and problematic areas of tax settlements. The key team responsible for identifying areas of tax risk is the Accounting Department, which operates within the Shared Services Centre. This unit is responsible for the tax and accounting support of the Company, involving experts with deep knowledge, extensive practical skills and many years of experience in performing the above activities. Supervision over the operation of the Accounting Department, including in the area of tax risk management, is exercised by the President of the Management Board. In performing tax obligations, the Company’s Management Board and Accounting Department use the support of the Tax Advisory Office Verum Mariusz Raszczyk i Wspólnicy Sp. k.
Information on voluntary forms of cooperation with the National Revenue Administration authorities
In 2021, the Company did not use any voluntary forms of cooperation with the National Revenue Administration, including did not seek participation in the Cooperation Programme.
Information on the performance by the Taxpayer of tax obligations in the territory of the Republic of Poland
6.1 General information
In 2021, the Company was a taxpayer of the following taxes:
value added tax (VAT);
corporate income tax (CIT).
6.2 Information on the number of reports submitted to the Head of the National Revenue Administration on tax schemes referred to in Article 86a § 1(10) of the Tax Ordinance
The Company did not submit to the Head of the National Revenue Administration any information on tax schemes referred to in Article 86a § 1(10) of the Tax Ordinance.
Information on transactions with related entities
In the year beginning on 1 January 2021 and ending on 31 December 2021, the Company concluded with related entities transactions whose value, taking into account data aggregation, exceeded 5% of the balance sheet total of assets. Transactions with related entities mainly consisted of:
sale of goods to related entities;
provision of services to related entities;
purchase of goods from related entities.
Information on restructuring activities planned or undertaken by the taxpayer which may affect the amount of the taxpayer’s or related entities’ tax liabilities within the meaning of Article 11a(1)(4) CITA
In the year beginning on 1.01.2021 and ending on 31.12.2021, the Company did not undertake restructuring activities that could affect the amount of the Company’s or related entities’ tax liabilities.
Information on applications submitted by the taxpayer:
9.1 For the issuance of a general tax ruling referred to in Article 14a § 1 of the Tax Ordinance
In 2021, the Company did not apply for a general tax ruling.
9.2 For the issuance of an interpretation of tax law provisions referred to in Article 14b of the Tax Ordinance
In 2021, the Company submitted applications for individual rulings regarding the tax consequences (VAT, PCC, CIT) of a special type of transaction. The conditions for concluding the transaction are covered by trade secrecy.
9.3 For the issuance of a binding rate information (WIS) referred to in Article 42a of the VAT Act
In 2021, the Company did not apply for a binding rate information.
9.4 For the issuance of a binding excise information referred to in Article 7d(1) of the Excise Duty Act
In 2021, the Company did not apply for a binding excise information.
Information on the taxpayer’s tax settlements in territories or countries applying harmful tax competition indicated in implementing acts issued under Article 11j(2) CITA and Article 23v(2) of the Personal Income Tax Act and in the notice of the minister competent for public finance issued under Article 86a § 10 of the Tax Ordinance
In the 2021 tax year, the Company did not make tax settlements in territories or countries applying harmful tax competition.