Succession of the right to comply with individual interpretations of tax law provisions and the protection resulting therefrom
This article concerns the issue of the succession of the right to comply with an individual interpretation and the protection provided on its basis. The possibility for the legal successor to benefit from the interpretation, as well as the security and guarantee of protection provided under art. 14k...
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| Format: | Article |
| Language: | English |
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Wydawnictwo Naukowe Uniwersytetu Mikołaja Kopernika
2023-09-01
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| Series: | Prawo Budżetowe Państwa i Samorządu |
| Subjects: | |
| Online Access: | https://apcz.umk.pl/PBPS/article/view/48478/38476 |
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| Summary: | This article concerns the issue of the succession of the right to comply with an individual interpretation and the protection provided on its basis. The possibility for the legal successor to benefit from the interpretation, as well as the security and guarantee of protection provided under art. 14k - 14m o.p. is an issue that raises a lot of controversy. Both in case law and among representatives of the doctrine, there are opposing positions on the question of how to interpret the provisions indicated in art. 93 § 1 o.p. entering in "all" of the rights and obligations of each of the merging persons or companies provided for in the provisions of tax law. Discrepancies and limitations in this respect make it difficult for taxpayers to arrange and plan in a safe manner significant tax-related projects. Especially those related to their business activities. The article presents the principles of succession of rights resulting from individual interpretation. Basic information about interpretation is provided. General considerations concerning the nature of interpretation are discussed. |
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| ISSN: | 2300-9853 2353-7086 |