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The issue of recognizing the sale of shares in subsidiaries as sporadic activities

The Provincial Administrative Court in Warsaw ruled that the company’s share transactions should be considered ancillary, as the company’s resources were minimally involved. The company has the right to sell shares to accumulate capital for further investments without affecting tax deductions. The court also noted that the company required external assistance for the legal service of the transactions, indicating their ancillary nature.

Source PwC

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