Tax strategy

Information about the implemented tax strategy
for the tax year from January 1 to December 31, 2022.

Bizea sp. z o. o

Contents

1. Entry
2. Information about the implemented tax strategy
3. Information on the applied processes and procedures for managing the performance of obligations arising from tax law provisions and ensuring their correct implementation 
4. Information about voluntary forms of cooperation with KAS authorities.
5. Information regarding the taxpayer's fulfillment of tax obligations in the territory of the Republic of Poland, along with information on the number of information on tax schemes provided to the Head of the National Tax Administration, broken down into the taxes they concern.
6. Information on transactions with related entities whose value exceeds 5% of the balance sheet total of assets within the meaning of accounting regulations, determined on the basis of the last approved financial statements of the Company, including entities that are not tax residents of the Republic of Poland
7. Information about restructuring activities planned or undertaken by the Company that may affect the amount of tax liabilities of the taxpayer or related entities.
8. Information about applications submitted by the taxpayer for the issuance of official letters.
9. Information regarding tax settlements in territories or countries applying harmful tax competition indicated in implementing acts issued pursuant to Art. 11j section 2 of the CIT Act and in the announcement of the minister responsible for public finances issued pursuant to Art. 86a § 10 of the Tax Ordinance

List of shortcuts

1. Introduction

Bizea distributes pneumatic nailers and fasteners: staples, pins, nails and various special connectors, as well as the distribution and service of connecting devices and circular saws for cutting strips of picture frames, furniture, etc. produced by an external manufacturer.

Basic data about the Company is provided below.

Table 1. Basic financial information about the Company for 2022

Proper performance of the Company's tax obligations is one of the basic areas of its responsibility as a taxpayer and payer.

The Company's goal is also to eliminate tax risk related to transactions undertaken in the course of its business.

The above effect is achieved by using processes, procedures and methods of conduct that were implemented with the intention of creating an environment in the Company conducive to tax analysis. Conducting an appropriate tax analysis is extremely important because it aims to ensure compliance of settlements with tax regulations and to identify and eliminate irregularities early enough.

Bizea strives to conduct tax settlements in a primarily safe manner and is not interested in seeking tax savings through any aggressive tax optimization. The Company's decisions are always conditioned by economic issues and have business justification.

2. Information about the implemented tax strategy

This document contains information about the tax strategy implemented for 2022 and constitutes the fulfillment of the obligation imposed on the Company under Art. 27c of the CIT Act.

3. Information on the applied processes and procedures for managing the performance of obligations arising from tax law provisions and ensuring their correct implementation

In order for the tax obligations imposed on the Company by law to be performed in a reliable and timely manner, the Company has implemented processes and procedures that regulate their proper fulfillment.

The processes and procedures in question concern:

• division of tasks, powers and responsibilities in the performance of tax obligations and supervision over the correctness of settlements;
• substantive tax issues;
• personnel and tax knowledge management;
• verification of factual and legal circumstances regarding the conclusion of economic transactions;
• document circulation;
• exercising due diligence in VAT;
• verification of contracts by the legal department;
• supervision over the correctness of tax settlements;
• cooperation with tax advisors;
• rules for requesting individual interpretations;
• cooperation with tax authorities.

If the proper performance of tax obligations requires it, Bizea regulates internal processes and rules of conduct through formal procedures, guidelines, regulations, etc. They constitute internal documents of the Company and are not subject to disclosure or publication.

4. Information about voluntary forms of cooperation with KAS authorities

Pursuant to Chapter 1 of the Tax Ordinance, the Head of the National Tax Administration may conclude a cooperation agreement with a taxpayer, which serves to ensure compliance by the taxpayer with the provisions of tax law in conditions of transparency of actions taken and mutual trust and understanding between the tax authority and the taxpayer, taking into account the nature of the taxpayer's business.

Pursuant to Chapter 2 of the Act on the settlement of disputes regarding double taxation and the conclusion of prior pricing agreements, the Head of the National Tax Administration, at the request of a domestic related entity, issues a prior pricing agreement, which constitutes a decision in which it is deemed that the transfer price of the controlled transaction was established on terms that would establish between unrelated entities.

The Company's goal is to maintain good relations with the KAS authorities, which is achieved, among others, by: by timely provision of all required documents, information and explanations at the request of the authorities.

In 2022, Bizea did not undertake voluntary forms of cooperation with KAS authorities,
in particular, it did not participate in the Cooperation Program with KAS and did not enter into prior pricing agreements.

5. Information regarding the taxpayer's fulfillment of tax obligations in the territory of the Republic of Poland, along with information on the number of information on tax schemes provided to the Head of the National Tax Administration, broken down into the taxes they concern.

The Company's goal is to best meet its tax obligations in the territory of the Republic of Poland. The Company's priorities include ensuring that its tax settlements are carried out correctly, timely and in accordance with applicable tax law by appropriately qualified persons and engaged tax advisors.

Bizea is aware that despite exercising due diligence in conducting tax settlements, there is a risk of irregularities. Therefore, the Company's objectives also include early detection of irregularities and their immediate removal (including submitting corrections to declarations and settling any tax arrears along with any due interest).

In 2022, the Company was a taxpayer of the following taxes:

• tax on goods and services (VAT),
• corporate income tax (CIT).

Moreover, in the year in question, the Company was a payer of personal income tax (PIT) on remuneration paid to employees.

In 2022, the Company did not provide the Head of the National Tax Administration with information on tax schemes - events constituting a tax scheme/schemes did not occur in the Company's operations.

6. Information on transactions with related entities whose value exceeds 5% of the balance sheet total of assets within the meaning of accounting regulations, determined on the basis of the last approved financial statements of the Company, including entities that are not tax residents of the Republic of Poland

In business transactions with related entities, Bizea applies the conditions that would apply to unrelated entities (so-called market principles). If the Company meets the statutory requirements, Bizea prepares appropriate transfer pricing documentation and performs the necessary reporting obligations in this respect.

In 2022, the Company concluded transactions with related entities whose value exceeded 5% of the balance sheet total of assets within the meaning of the regulations
on accounting, determined on the basis of the approved financial statements of the Company for 2021, including:

• sales of goods (staples, connectors, etc.),
• purchase transactions of goods (staples, pins, etc.),
• real estate lease transactions

and other transactions concluded by the Company in the course of its operations.

 The details of the above transactions are subject to commercial confidentiality.

7. Information about restructuring activities planned or undertaken by the Company that may affect the amount of tax liabilities of the taxpayer or related entities

Bizea does not undertake restructuring activities that would be aimed at obtaining a tax advantage for the Company that is contrary to the purpose and subject of tax law. All restructuring is carried out in particular based on economic and business reasons. Tax settlements relating to this type of activities are consulted with tax advisors to ensure their correct conduct.

In 2022, Bizea did not undertake any restructuring activities^[1]that could affect the amount of tax liabilities of the Company or its related entities.

No restructuring is planned for 2022 and subsequent fiscal years.

8. Information about applications submitted by the taxpayer for the issuance of official letters

Pursuant to Art. 14a of the Tax Ordinance, the minister responsible for public finances strives to ensure uniform application of tax law provisions by tax authorities, among others: by interpreting them, ex officio or upon request (general interpretations), taking into account the case law of courts, the Constitutional Tribunal or the Court of Justice of the European Union.

As indicated in Art. 14b of the Tax Ordinance, the Director of the National Tax Information, at the request of the interested party, issues, in his individual case, an interpretation of the provisions of tax law (individual interpretation), which may concern the actual state of affairs or future events.

Binding rate information – in accordance with Art. 42a of the VAT Act - is a decision issued for the purposes of taxing the supply of goods, the import of goods, the intra-Community acquisition of goods or the provision of services. Binding rate information includes a description of the goods or services that are the subject of WIS, the statistical classification and the tax rate applicable to the goods or services.

Binding excise information – in accordance with Art. 7d of the Excise Duty Act
– is a decision issued for the purposes of taxing an excise goods or a passenger car with excise duty, organizing trade in excise goods or marking these goods with excise stamps, which determines the classification of the excise goods or a passenger car in the system corresponding to the Combined Nomenclature (CN) or the type of excise goods by the description of this product in to such a level of detail that is sufficient to determine the taxation of excise goods with excise duty, to organize trade in excise goods or to mark these products with excise stamps.

Individual tax interpretations issued at the Company's request constitute a tool for resolving tax doubts that cannot be removed in any other way. Bizea has implemented rules for obtaining individual interpretations, which improve the decision-making process in this area.

In 2022, Bizea submitted an application for the issuance of:

• individual interpretation of tax law provisions regarding the provisions of the Act of February 15, 1992 on corporate income tax in connection with the planned use of lump-sum taxation on company income.

Bizea did not submit an application in 2022 for the issuance of:

• general tax interpretation,
• binding rate information,
• binding excise information.

9. Information regarding tax settlements in the territories
or in countries applying harmful tax competition as indicated
in implementing acts issued pursuant to Art. 11j section 2 of the CIT Act and
in the announcement of the minister responsible for public finances issued pursuant to Art. 86a § 10 of the Tax Ordinance

In 2022, the Company did not settle taxes in territories or countries applying harmful tax competition indicated in the relevant implementing acts and the relevant announcement of the minister responsible for public finances.

[1] Understood as a merger of companies, transformation of a company into another company, contribution to the company in the form of the company's enterprise or an organized part thereof (including as part of the division of the company) and exchange of shares, as well as debt restructuring.