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The Pillar Two Model Rules address tax challenges of the digitalization of the economy that was agreed upon by almost 140 countries of OECD/G20. The rules are designed in a way that ensures that large multinational enterprises pay a minimum level of on the income arising in each jurisdiction where they operate.
On behalf of the AmCham Tax & Financial Services Committee, we invite you to a meeting entitled
Pillar II (Global Minimum Tax) – How to Manage your Compliance Obligations? Our speakers will be Maciej Żurek and Mariusz Każuch, Partner Associates, and Marcin Becela, Senior Manager, from Deloitte, AmCham member company. During our meeting, we will discuss the practical aspects of the proposed changes and their impact on businesses, including: Pilar II - status of the implementation and the impact on transfer pricing rules; Polish local concept of minimum corporate tax versus global concept; Scope of the regulations; Tax base subject (GloBE income) and Tax amount subject (Adjusted Covered Taxes); The Calculation of the effective tax rate (Effective Tax Rate) and tax liability (Top-up Tax); The role of technology in tax reporting and calculation processes.
The meeting will take place on Wednesday, May 24, from 9:30 a.m. to 10:30 a.m. and will be held in Polish. We encourage you to visit the AmCham office, Spektrum Tower, ul. Twarda 18, 16th floor (live tickets are limited to 20 people, for those registering live, we ask you to click the live ticket). The Webex link will be sent to all online attendants before the event.
Speakers Speakers Marcin Becela Senior Manager at DELOITTE POLAND Sp. z o.o. Marcin Becela Senior Manager at DELOITTE POLAND Sp. z o.o.
Marcin is a lawyer by education. He also completed post-graduate studies in Project Management at the Warsaw University of Technology.
Marcin has over ten years of experience in tax advisory, including the corporate income tax, international tax law, as well as automation of processes in the CIT area. For over two years Marcin has been involved in automation projects covering a wide spectrum of activities from creation to configuration of IT solutions. Activities in this area include both the automation of entire processes, such as the CIT calculation process using dedicated tools, as well as smaller parts of the process, such as the automation of declarations and information submission or the automation of repetitive activities performed daily in the tax and accounting departments of companies. For over three years, Marcin was involved in a comprehensive ongoing tax services for a leading telecommunication company. The project consisted of a partial secondment as an internal advisor. The role included, in particular, verification of CIT and WHT calculations and declarations, tax analysis of contracts and other documents as well as tax support in the Client's business processes. Marcin also held a position of an interim-tax-manager in one of the leading fuel industry companies. Mariusz Każuch Partner Associate at DELOITTE POLAND Sp. z o.o. Mariusz Każuch Partner Associate at DELOITTE POLAND Sp. z o.o.
In 2016 and 2023, Mariusz served as the Deputy Director of the Department at the Polish Ministry of Finance, responsible for transfer pricing MAP and APA negotiations, the transfer pricing policy and legislation. Prior to that, in the period 2012–2016, Mariusz held the position of the Deputy Director of the Tax Policy Department (MoF) responsible for the tax policy, double tax treaty negotiations and international cooperation. He was also the Polish delegate to many OECD and EU working groups, i.a. WP no. 1 on Tax Conventions and Related Questions and WP no. 6 (transfer pricing). Mariusz supervised the process of negotiation of more than 50 international agreements, including 36 double tax treaties.
He is the author of the special petroleum fiscal system in Poland and the co-author of the copper and silver extraction tax law. He participated in many fiscal projects, i.a. trainings for the Zambian and Kenyan tax authorities concerning the tax policy for extraction of mineral resources. Mariusz managed the FATCA and CRS implementation process in Poland. He was also responsible for the GAAR introduction process. He gained practical experience in fiscal audits during his several years as a tax inspector specializing in the insurance and banking sector. In Deloitte, Mariusz has been involved in numerous APAs, MAPs and controversy cases for multinationals operating in various industries, including energy, automotive, consumer goods, banks and entertainment. Mariusz is a certified tax advisor. Maciej Żurek Partner Associate at DELOITTE POLAND Sp. z o.o. Maciej Żurek Partner Associate at DELOITTE POLAND Sp. z o.o.
Maciej is a lawyer and licensed tax advisor, he has been working at Deloitte since 2010. During this time, Maciej supervised many tax projects in such areas like organizational and financial structuring in multinational capital groups, tax review of inter-company transactions and flows, tax risk assessment and management, international tax law, tax reporting, etc.
Maciej has extensive experience in ongoing tax advisory and tax reviews, including tax reviews for purposes of audit of statutory financial statements. He is specializing in advisory for MNC clients (multinational corporations) from diverse industries such as technology, media and telecommunications (TMT), FMCG and heavy industry. Maciej conducted many tax proceedings, including assistance in tax audits and after-audit disputes; assistance in obtaining of tax rulings, GAAR protective opinions and WHT clearance opinions. Welcome to Glue Up. We are upgrading our password strength service in order to align with ISO27001 standards. Please take a moment to upgrade your password.
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