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Celsa Polska Holding

Information on the implementation of the tax strategy for 2020

By CELSA Polska Holding Spółka z ograniczoną odpowiedzialnością (hereinafter the 'Company') for the tax year from 1 January 2020 to 31 December 2020 published pursuant to Article 27c(1) of the Corporate Income Tax Act of 15 February 1992

In general, the Company's tax strategy focuses on:

• Pursue the proper fulfilment of all tax obligations incumbent on the Company and timely filing of all relevant tax returns and payment of all taxes in accordance with Polish law.
• Analysis of the tax consequences of business decisions.
• Compliance with internal processes and procedures related to tax risk management.

For the fiscal year running from January 1, 2020 to December 31, 2020. (hereinafter: the "tax year") the Company:

1. Applied, in particular, the following processes and procedures to manage and ensure the proper performance of its obligations under tax law in the following areas:
• Corporate income tax.
• Personal income tax.
• Countering the failure to comply with the obligation to provide information on tax schemes (MDR).


2. Did not participate in voluntary forms of cooperation with the National Fiscal Administration authorities, in particular was not a party to a tax cooperation agreement within the meaning of Article 20s § 1 of the Tax Ordinance Act of 29 August 1997 (Journal of Laws of 2021, item 1540, hereinafter the "Tax Ordinance") or a prior agreement on pricing (APA).


3. Has fulfilled in a timely manner and to the best of its knowledge all its tax obligations in the Republic of Poland with respect to corporate income tax, personal income tax.


4. Did not submit information on tax schemes referred to in Article 86a § 1 point 10 of the Tax Ordinance.


5. Has concluded the following transactions with related entities within the meaning of Article 11a par. 1 pt. 4 of the CIT Act, the value of which exceeds 5% of the balance sheet total of assets within the meaning of the accounting regulations, determined on the basis of the Company's last approved financial statements, including entities which are not tax residents of the Republic of Poland:
• Obtaining a loan.
• Sale of shares in a subsidiary.


6. Did not plan or undertake restructuring activities in 2020 which may affect the amount of its tax liabilities or tax liabilities of related entities within the meaning of Article 11a par. 1 point 4 of the CIT Act.


7. In the tax year to which this information on the implementation of the tax strategy relates, the Company did not apply for:
• General tax interpretation referred to in Article 14a § 1 of the Tax Ordinance.
• Applications for the issuance of individual interpretations of the provisions of tax law referred to in Article 14b of the Tax Ordinance.
• Binding rate information referred to in Article 42a of the Act of 11 March 2004 on Goods and Services Tax (i.e. Journal of Laws of 2021, item 685).
• The binding excise duty information referred to in Article 7d, paragraph 1 of the Act of 6 December 2008 on Excise Duty (the Act of Law of 2020, item 722 and 1747).


8. Did not settle taxes in the territories or countries applying harmful tax competition designated in implementing acts issued on the basis of:
• Article 11j(2) of the CIT Act, i.e. in the Regulation of the Minister of Finance of 28 March 2019 on the determination of countries and territories applying harmful tax competition with respect to corporate income tax (Journal of Laws 2019, item 600).
• Article 11j(2) of the CIT Act, i.e. in the Regulation of the Minister of Finance of 28 March 2019 on the determination of countries and territories applying harmful tax competition with respect to corporate income tax (Journal of Laws 2019, item 600).
• In the announcement of the minister competent for public finance issued pursuant to Article 86a § 10 of the Tax Ordinance, i.e. in the announcement of the Minister of Finance, Funds and Regional Policy of 12 October 2020 on publishing the list of countries and territories indicated in the EU list of non-cooperative jurisdictions for tax purposes adopted by the Council of the European Union which are not included in the list of countries and territories applying harmful tax competition issued under the provisions on personal income tax and the provisions on corporate income tax, and the date of adoption of that list by the Council of the European Union (M.P. pos. 925).