INFORMATION ON THE TAX STRATEGY IMPLEMENTED BY ADOB SP. Z O.O.
FOR TAX YEAR 2022
Information about the Tax Strategy implemented by Przedsiębiorstwo Produkcyjno-Consultingowe ADOB Sp. z o.o. (hereinafter also referred to as the “Company”) was prepared and published pursuant to Art. 27c of the Act of February 15, 1992 on corporate income tax (consolidated text: Journal of Laws of 2021, item 1800, as amended, hereinafter referred to as the “CIT Act”)
1. GENERAL INFORMATION ABOUT THE COMPANY AND THE MAIN ASSUMPTIONS OF ITS TAX STRATEGY
ADOB Sp. z o. o. was founded in 1990. The company is based in Poznań and was entered into the register of entrepreneurs kept by the District Court for the city of Poznań, VIII Commercial Division of the National Court Register under KRS number: 0000966321.
ADOB Sp z o. o. is one of the largest producers of foliar fertilizers in Poland. It specializes in the production of microelement chelates.
It offers fertilizers for agricultural, vegetable and orchard crops, fertigation and hydroponics on the domestic and international market.
Full information about the company’s activities, products and services offered can be found at: www.adob.com.pl
The company operates in an ethical and socially responsible manner.
Tax issues are and have been treated by the Company with proper care. Tax settlements are made in accordance with applicable tax law provisions.
2. INFORMATION ON THE TAXPAYER’S PROCESSES AND PROCEDURES RELATED TO MANAGING THE PERFORMANCE OF OBLIGATIONS ARISING FROM TAX LAW AND ENSURING THEIR CORRECT FULLFILMENT
The Company pays taxes in accordance with all applicable rules and regulations. In doing so, the Company aim to comply with both the letter and the spirit of the law. The Company prepares and files all required tax returns, providing complete, accurate and timely disclosures to all relevant tax authorities. For this purpose, the Compay employs appropriately qualified and trained tax professionals or engage reputable external tax advisors with an understanding of the company’s business.
The Company is committed to doing business ethically and responsibly, and this is no different when it comes to taxation. In managing tax affairs, the Company’s employees must adhere to the Internal Work Regulation of the Company.
All decisions are made by the Company primarily on the basis of economic and business considerations, not tax considerations.
In relation to transactions with related entities, the Company complies with transfer pricing regulations and the arm’s length principle in this regard.
The Company seeks an open and constructive dialog with tax authorities through the disclosure of relevant facts and circumstances. The Company is open with tax authorities, responding to relevant tax authority enquiries in a timely manner to assist in the evaluation of filings and disclosures as well as the consequential tax liability.
The Company uses the ERP system and other IT tools that support employees in the correct and timely fulfillment of the Company’s obligations arising from tax law provisions.
The Company has a tax management and control system, which ensures that the relevant functions are aware of tax risks and have sufficient insights to adequately address these risks.
Activities to prevent tax risk include: ongoing analysis of applicable regulations and planned amendments, monitoring the practice of tax authorities and the jurisprudence of administrative courts, cooperation with external law and tax consulting firms, and participation in adequate internal and external training.
In the Company’s opinion, the procedures and processes in place allow for proper management of tax functions and limitation of tax risk areas.
3. INFORMATION ON VOLUNTARY FORMS OF COOPERATION USED BY THE TAXPAYER WITH NATIONAL TAX ADMINISTRATION AUTHORITIES
During the year 2022, the Company has not entered into voluntary forms of cooperation with the authorities of the National Tax Administration (it has not concluded a cooperation agreement with the Head of the National Tax Administration, nor has it submitted an application / does not apply an APA prior pricing agreement).
4. INFORMATION ON THE COMPANY’S IMPLEMENTATION OF TAX OBLIGATIONS IN THE TERRITORY OF THE REPUBLIC OF POLAND, ALONG WITH INFORMATION ON THE NUMBER OF INFORMATION ON TAX SCHEMES REFERRED TO IN ART. 86A § 1 POINT 10 OF THE TAX ORDINATION (mandatory disclosure rules), WITH A DIVISION OF THE TAXES TO WHICH THEY CONCERN
As a consequence of the growth and development of the Company’s activities, the management board of ADOB Sp z o.o. has decided to change the form of business from a general partnership to a limited liability company. This transformation took place on June 1, 2022.
Therefore, the first fiscal year for which the Company submitted corporate tax settlements was shorter than the calendar year and lasted from June to December 2022.
The Company submitted the annual tax return and other declarations/information required by the CIT Act. The company also fulfilled its function as a payer of flat-rate corporate income tax.
The company is an active VAT payer. The company submitted uniform control files and summary information every month, within the statutory deadline.
The company is a payer of personal income tax and social security contributions for its employees. The company submitted PIT-4R and PIT-11 declarations to the relevant tax offices within the statutory deadline.
The company is a real estate tax payer. The company submitted the DN-1 declaration and paid the real estate tax.
In 2022, the company did not provide information on tax schemes.
5. INFORMATION ABOUT TRANSACTIONS WITH RELATED ENTITIES WITHIN THE MEANING OF ART. 11A SECTION 1 POINT 4 OF THE CIT ACT, WHICH VALUE EXCEEDS 5% OF THE BALANCE SHEET TOTAL OF ASSETS WITHIN THE MEANING OF THE ACCOUNTING REGULATIONS ESTABLISHED ON THE BASIS OF THE LAST APPROVED FINANCIAL STATEMENT OF THE COMPANY, INCLUDING ENTITIES THAT ARE NOT TAX RESIDENTS OF THE REPUBLIC OF POLAND
In the tax year 2022, the Company concluded transactions with related entities (within the meaning of Article 11a(1)(4) of the CIT Act), the value of which exceeds 5% of the balance sheet total of the Company’s assets. These transactions concern the purchase of chemical products from Zakłady Chemiczne Zlotniki Sp. z o. o.
6. INFORMATION ON RESTRUCTURING MEASURES PLANNED OR UNDERTAKED BY THE TAXPAYER THAT MAY AFFECT THE AMOUNT OF TAX OBLIGATIONS OF THE TAXPAYER OR RELATED ENTITIES WITHIN THE MEANING OF ART. 11A SECTION 1 POINT 4
As mentioned earlier, as a consequence of the growth and development of the Company’s activities, the owners of ADOB Sp. z o.o. decided to change the form of business from a general partnership to a limited liability company.
This transformation took place on June 1, 2022. Therefore, the first tax year for which the Company submitted tax settlements was shorter than the calendar year and lasted from June to December 2022.
In 2022, and other than the restructuring mentioned above, the Company did not undertake or plan any restructuring activities, including those that could affect the amount of tax liabilities of the Company.
7. INFORMATION ON APPLICATIONS SUBMITTED BY THE COMPANY FOR A GENERAL TAX INTERPRETATION (REFERRED TO IN ARTICLE 14A, PAR. 1 OF THE TAX ORDINATION), AND FOR INTERPRETATION OF TAX LAW PROVISIONS (REFERRED TO IN ARTICLE 14B OF THE TAX ORDINATION), BINDING RATE INFORMATION (ABOUT WHAT REFERRED TO IN ARTICLE 42A OF THE GOODS AND SERVICES TAX ACT) OR BINDING EXCISE INFORMATION (REFERRED TO IN ARTICLE 7D(1) OF THE EXCISE TAX ACT)
In 2022, the Company did not apply for a general tax interpretation, binding rate information or binding excise information.
In 2022, the Company did not apply to the Director of the National Tax Information for an individual interpretation of tax law.
8. INFORMATION REGARDING THE COMPANY’S TAX SETTLEMENTS IN TERRITORIES OR COUNTRIES APPLYING HARMFUL TAX COMPETITION INDICATED IN THE EXECUTIVE ACTS ISSUED PURSUANT TO ART. 11J SECTION 2 OF THE ACT OF FEBRUARY 15, 1992 ON INCOME TAX FROM CORPORATE PERSONS AND PURSUANT TO ART. 23V SET. 2 OF THE ACT OF 26 JULY 1991 ON INCOME TAX FROM INDIVIDUALS AND IN THE ANNOUNCEMENT OF THE MINISTER COMPETENT FOR PUBLIC FINANCE ISSUED PURSUANT TO ART. 86A § 10 TAX ORDINATION
In the tax year 2022, the Company did not settle taxes in territories or countries applying harmful tax competition, indicated in implementing acts issued pursuant to Art. 11j section 2 of the Act of February 15, 1992 on corporate income tax and pursuant to Art. 23v section 2 the Act of 26 July 1991 on personal income tax and in the announcement of the minister responsible for public finances issued pursuant to Art. 86a § 10 of the Tax Ordinance.