Holding company location: a Polish tax perspective

This paper aims to present the size and structure of passive income payments, such as dividends, interest, royalty payments, and fees for intangible services, made by companies domiciled in Poland belonging to a multinational enterprises (MNE) group. The authors formulate a hypothesis that tax jurisdictions offering extensive legal and tax incentives for holding structures, in particular concerning the tax treatment of dividends and other withholding tax payments, are the preferred location of holding companies. A review of the literature and legal sources precedes empirical research. The empirical analysis shows that passive income flows, including dividends, interest, royalties, and fees for intangible services, which constitute the dominant type of payments to holding companies, are directed from Poland primarily to countries with tax and regulatory solutions that are friendly to holding companies, including in particular the so-called intra-EU tax havens, namely Luxembourg, Cyprus, the Netherlands, Malta and Ireland. Real trade with these countries is neither significant nor proportional to the scale of passive income.This paper aims to present the size and structure of passive income payments, such as dividends, interest, royalty payments, and fees for intangible services, made by companies domiciled in Poland belonging to a multinational enterprises (MNE) group. The authors formulate a hypothesis that tax jurisdictions offering extensive legal and tax incentives for holding structures, in particular concerning the tax treatment of dividends and other withholding tax payments, are the preferred location of holding companies. A review of the literature and legal sources precedes empirical research. The empirical analysis shows that passive income flows, including dividends, interest, royalties, and fees for intangible services, which constitute the dominant type of payments to holding companies, are directed from Poland primarily to countries with tax and regulatory solutions that are friendly to holding companies, including in particular the so-called intra-EU tax havens, namely Luxembourg, Cyprus, the Netherlands, Malta and Ireland. Real trade with these countries is neither significant nor proportional to the scale of passive income

CIT „estoński” – wątpliwości na gruncie prawa podatkowego i bilansowego

The aim of the article is to present the uncertainties arising from the analysis of regulations concerning flat-rate tax on the income of companies, both in terms of tax law and accounting law. The correct determination of the tax base for personal income tax on the part of partners receiving profits appears to be particularly problematic. An analysis of tax rulings issued by the Director of the National Revenue Administration indicates a contradiction in the positions presented in this regard. Tax rulings issued also often conflict with the tax explanations from the Ministry of Finance dated December 23, 2021, as well as with the views presented in the subject literature. This issue affects the amount of distributed profits to the partners of the companies and the amount of personal income tax (PIT) due thereby creating a tax risk for the taxpayer. Based on the analysis of the literature, legal acts, previously issued individual interpretations and administrative court rulings, recommendations will be formulated regarding the future shape of regulations concerning the flat-rate tax on the income of companies, with the aim of eliminating interpretational uncertainties in this field and making the relevant regulations more transparent for both taxpayers and tax authorities. The next step, after changing tax explanations, should be a discussion on changing the financial statements of entities applying the flatrate tax on corporate income as in its current form, the ‘net profit’ position cannot be treated equivalently to the amount allocated for distribution.Celem artykułu jest przedstawienie wątpliwości powstałych na gruncie analizy przepisów dotyczących ryczałtu od dochodów spółek, zarówno na gruncie prawa podatkowego, jak i prawa bilansowego. Szczególnie problematyczne zdaje się być prawidłowe ustalenie podstawy opodatkowania podatkiem od osób fizycznych po stronie wspólnika otrzymującego zysk. Analiza interpretacji indywidualnych Dyrektora Krajowej Informacji Skarbowej wskazuje na sprzeczność stanowisk prezentowanych w tym zakresie. Wydawane interpretacje indywidualne nierzadko pozostają w sprzeczności również z objaśnieniami podatkowymi Ministerstwa Finansów z 23.12.2021 r. oraz z poglądami prezentowanymi w literaturze przedmiotu. Kwestia ta rzutuje na wysokość podzielonego zysku przypadającego wspólnikom tych spółek oraz wysokość należnego z tego tytułu PIT i tym samym skutkuje powstaniem ryzyka podatkowego po stronie podatnika. Na podstawie przeprowadzonej analizy literatury przedmiotu, aktów prawnych, wydanych dotychczas interpretacji indywidualnych oraz wyroków sądów administracyjnych sformułowano zalecenia co do przyszłego kształtu przepisów dotyczących ryczałtu od dochodów spółek, mające na celu eliminację wątpliwości interpretacyjnych na tym polu i tym samym sprawienie, by przedmiotowe przepisy stały się bardziej przejrzyste zarówno dla podatników, jak i organów podatkowych. Kolejnym krokiem po zmianie objaśnień podatkowych powinna być dyskusja nad zmianą układu sprawozdań finansowych jednostek stosujących ryczałt od dochodów spółek, gdyż w obecnym kształcie pozycja „zysku netto” nie może być traktowana równoważnie z kwotą przeznaczoną do podział

The performance of triglyceride to high-density lipoprotein cholesterol ratio in acute coronary syndromes using a diagnostic decision tree

Background. Modern modeling techniques, including decision trees, may potentially provide accurate prediction and classification of outcomes, and support the process of clinical decision making. The objective of our study was to evaluate the performance of triglyceride to high-density lipoprotein (TG:HDL-C) ratio in acute coronary syndromes (ACS) presented using a decision tree analysis. Methods. The initial study group consisted of 220 consecutive patients admitted to hospital within the first 6 hours from the onset of chest pain. All these patients met clinical criteria of ACS and were compared with 116 healthy volunteers in a case-control study. Serum was assayed on admission for cardiac troponin I, C-reactive protein, apolipoproteins ApoAI and ApoB, and lipid parameters. Atherogenic lipid ratios: TC:HDL:C, LDL-C:HDL:C and TG:HDL-C were calculated. Results. ACS patients showed almost twice as high median values of TG:HDL-C as controls [2.77 (1.88–4.08) vs. 1.47 (0.99–2.08); p < 0.0001]. The TG:HDL-C ratio was significantly related to the positive history of coronary artery disease, age and lipid parameters, except for LDL-C. The TG:HDL-C ratio was, after age, the most powerful independent predictor and classifier of the occurrence of ACS with the optimal cutoff being 2.28. The performance of TG:HDL-C was superior to other lipid parameters and ratios, and enabled identification of the additional 6 subjects with ACS. Conclusion. The TG:HDL-C ratio is a useful risk marker of the ACS occurrence. Further prospective studies are needed to confirm our findings and clarify the interaction between TG and HDL-C concentrations in ACS patients

Potentials of Poland Introduction to Socio-Economic Geography of Poland for Foreigners

The idea to write this book arose a few years ago during classes with foreign students. Those young people came to Poland not only to study in the areas of their choice but also to get to know people and the country. At that time, we did not have concise, modern monograph on Polish geography in English devised for people for whom geography is not the main study area. This book is exactly that. We wanted it to fit the tradition of regional geography. It was important for us to deliver as much information about the country as possible in the most accessible way. At the same time, thanks to explanation boxes with basic notions we remind the readers what geography as a science deals with. We entitled the monograph “Potentials of Poland” believing that foreigners will discover in our country opportunities which they had never expected. We strived to present a constantly changing and advancing country. Even though the subtitle includes the phrase “socio-economic geography”, the book includes chapters on physical geography and the political situation in Poland. We believe they are an essential to the whole. We hope that the “Potentials of Poland. Introduction to Socio- Economic Geography of Poland for foreigners” will help students understand what they see around themselves and will encourage others to visit Poland

The problem of anemia in elderly patients

Introduction and purpose:  As healthcare develops, life expectancy increases. This makes anemia of the elderly an increasingly common problem. The appearance of this disease is influenced by many factors related to the aging process of the organism. The purpose of this study is to review information about the different mechanisms of anemia development in the elderly and to present the associated difficulties in medical practice. Description of the state of knowledge: Many different factors can affect the process of anemia. The causes of this disorder include chronic inflammatory diseases, cancer and nutritional deficiencies. Endocrine status is also important. The chronic inflammatory process may induce haemolysis and lead to the increased synthesis of hepcidin, which by blocking the activity of ferroportin leads to a decrease in the level of iron ions in the blood. Deficiency anemia often results from reduced appetite, inadequate quality of meals, chronic inflammation or taking medications without consulting a doctor. The consequence is a reduced level of iron and vitamin B12 and folic acid, which play a role in erythropoiesis. The hormones that play a significant role in the process of making red blood cells include erythropoietin, testosterone and thyroid hormones. Summary:  Anemia is a common problem among geriatric patients and one of the factors contributing to the increase in mortality in this age group. In medical care it is difficult to distinguish which symptoms are pathological and which are related to the natural aging process, overlapping symptoms of many diseases and related diagnostic problems. Diagnostics is a particular challenge due to the multi-morbidity, which is associated with taking many drugs with different mechanisms of action and side effects.  Keywords: anemia; aging; comorbidity; nutrient-deficiency anemia; inflammatio

Antidepressant-like activity and safety profile evaluation of 1H-imidazo[2,1-f]purine-2,4(3H,8H)-dione derivatives as 5-HT1A receptor partial agonists

Current antidepressant therapy has several disadvantages related to the properties of antidepressants. Considering their unfavourable features, the process of searching for new antidepressant drugs with better safety and tolerability requires consistent efforts and many complementary studies. Serotonin 5-HT1A receptor is considered as an interesting target of antidepressant therapy. In the present study, the intrinsic activity at different signaling pathways coupled to serotonin 5-HT1A receptor, antidepressant-like and pharmacokinetic properties, and the safety profile of two novel imidazopurine-2,4-dione derivatives, namely compounds AZ-853 (8-(4-(4-(2-fluorophenyl)piperazin-1-yl)butyl)-1,3-dimethyl-1H- imidazo[2,1-f]purine-2,4(3H,8H)-dione) and AZ-861 (1,3-dimethyl-8-(4-(4-(3-(trifluoromethyl)phenyl)piperazin-1-yl)butyl)-1H-imidazo[2,1-f]purine-2,4(3H,8H)-dione), were studied in animal models through in vitro and in vivo experiments. We demonstrated that AZ-853 and AZ-861, which structurally differ by one substituent and its placement in the phenyl ring, showed varied functional, pharmacological, and pharmacokinetic properties as well as side effect profiles. AZ-861 exhibited stronger agonistic action in all functional assays. After acute and repeated administration in mice, both compounds showed antidepressant-like activity in the forced swim test, which was partially mediated by 5-HT1A receptor activation. AZ-853 showed a more potent antidepressant-like effect, presumably due to its better penetration into brain structures. Both compounds did not show anticholinergic properties, but after repeated administration, they induced weak sedation and lipid metabolism disturbances without affecting serum glucose level. The stronger α1-adrenolytic effect of AZ-853 is responsible for decreased systolic blood pressure, and in contrast to AZ-861, AZ-853 induced weight gain in mice. The interesting comparative pharmacological profiles of AZ-853 and AZ-861 encourage to conduct further experiments to fully understand their mechanisms and differences in action

ARCHITECT STAT High Sensitive Troponin I Familiarization Study (FAM) in the Department of Laboratory Medicine, Collegium Medicum, Nicolaus Copernicus University in Bydgoszcz, Poland

Background. International guidelines recommend the use of cardiac troponin assays for early detection of acute myocardial infarction. New high-sensitivity assays along with improved precision and sensitivity, are now widely available, accelerating patient’s diagnosis, treatment and invasive therapy. In this study we evaluated analytical performance of the Abbott ARCHITECT STAT high-sensitive troponin-I immunoassay and its 99th percentile upper reference limit. Methods. We performed the analytical evaluation of the hs-cTnI assay using Abbott ARCHITECT i2000SR immunoanalyzers. Features of the assay including imprecision, detection limits, linearity of dilution, interferences and method comparisons were assessed, as well as the 99th percentile upper reference limits in a cohort of 427 presumably healthy individuals were established. Results. Total imprecision ranged from 3.1% to 4.7% and was lowest for the medium controls. The observed limit of blank, limit of detection and limit of quantitation assumed values of 0.1, 1.5 and 4.8 ng/L, respectively. Common interferences, sample dilution and carry over did not affect the hs-cTnI results. Hs-cTnI was detectable in 98% of presumably healthy individuals. The 99th percentile values were age and sex dependent in the presumably healthy, but not in the healthy individuals. Conclusion. The new high-sensitivity troponin-I assay has improved analytical features and may be a valuable diagnostic tool.

Molecular diagnostic tests for thrombophilia in patients referred to genetic counseling clinic because due to recurrent pregnancy failure. One center’s experience.

The loss of three or more subsequent pregnancies before the end of the 22nd week is observed in 0.4–1% of women. Despite great advances in medicine, the causes of pregnancy failure (miscarriages, missed abortions and stillbirths), and the birth of a child or children with congenital abnormalities, are still not determined precisely. The aim: The purpose of the research was to determine the association of polymorphisms and mutations of coagulation factors II and V genes, as well as methylenetethrahydrofolate reductase (MTHFR) gene polymorphism, with the course of pregnancy and the type of reproductive failure. Methods: The research was performed in a group of 116 women referred to the Genetic Outpatient Clinic of the NCU SM in Bydgoszcz between 2009–2010 due to reproductive failures. The molecular tests for thrombophilia, i.e. mutation of the factor V Leiden, prothrombin gene mutation 20210G>A, and MTHFR polymorphism 677C>T were done in all patients. Results: The Leiden mutation was found in 8 women (homozygotic in 2 of them) and prothrombin gene mutation in 3. 85 women had the heterozygotic MTHFR polymorphism, while 24 the homozygotic one. Coexistence of the Leiden mutation and the MTHFR polymorphism was found in 3 patients with history of miscarriages. Conclusions: 1. The presence of the mutations that promote thrombophilia in the genes responsible for the foliate metabolism and for the plasma coagulation is often associated with pregnancy failures and may be their basic cause in some cases. 2. The percentage of women with pregnancy failures being heterozygotes (73.3%), homozygotes (20.7%) or both (94%) of the MTHFR gene 677C>T polymorphism is statistically significantly higher than the highest prevalence of these changes in the general population (55, 13%, and 68%, respectively). 3. The factor V gene Leiden mutation is associated mainly with recurrent spontaneous abortions. In the present study it was found only in the group of women with both early and late miscarriages

Rapid method for Mycobacterium tuberculosis identification using electrospray ionization tandem mass spectrometry analysis of mycolic acids

Mycolic acids (MAs), which play a crucial role in the architecture of mycobacterial cell walls, were analyzed using electrospray ionization tandem mass spectrometry. A targeted analysis based on the 10 most abundant and characteristic multiple reaction monitoring pairs was used to profile the crude fatty acid mixtures from Mtb and several nontuberculous mycobacterial strains. Comparative analysis yielded unique profiles for MAs, enabling the reliable identification of mycobacterial species. In a case-control study of tuberculosis (TB) and non-TB Polish patients, we demonstrated the potential diagnostic utility of our approach for the rapid diagnosis of active TB with sensitivity and specificity surpassing those of existing methods. This robust method allows the identification of TB-positive patients after 2 h of sample preparation in the case of direct sputum analysis or 10 days of culturing, both of which are followed by 1 min of liquid chromatography– tandem mass spectrometry analysis

Assessing Various Control Samples for Microarray Gene Expression Profiling of Laryngeal Squamous Cell Carcinoma

Selection of optimal control samples is crucial in expression profiling tumor samples. To address this issue, we performed microarray expression profiling of control samples routinely used in head and neck squamous cell carcinoma studies: human bronchial and tracheal epithelial cells, squamous cells obtained by laser uvulopalatoplasty and tumor surgical margins. We compared the results using multidimensional scaling and hierarchical clustering versus tumor samples and laryngeal squamous cell carcinoma cell lines. A general observation from our study is that the analyzed cohorts separated according to two dominant factors: "malignancy", which separated controls from malignant samples and "cell culture-microenvironment" which reflected the differences between cultured and non-cultured samples. In conclusion, we advocate the use of cultured epithelial cells as controls for gene expression profiling of cancer cell lines. In contrast, comparisons of gene expression profiles of cancer cell lines versus surgical margin controls should be treated with caution, whereas fresh frozen surgical margins seem to be appropriate for gene expression profiling of tumor samples.</p