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Documents

  • Comments of the Polish Bank Association to the Green Paper on retail financial services (“Better products, more choice and greater opportunities for consumer and businesses”) pobierz plik pdf (0.172 MB)
  • The adoption of a tax on certain financial institutions

    Polish parliament has passed a law on the taxation of certain financial institutions.

    After a very rapid legislative process, a new solution has been adopted, which imposes a very strong additional tax burden for banks operating in Poland. During the parliamentary work the tax rate increased from 0.39% to 0.44% of assets.

    Dr Mariusz Zygierewicz, the Polish Bank Association's chief economist, explains that Polish banks pay taxes on general principles and as a sector contributes the highest corporate income tax to the state budget. He recalls at the same time that being entities supervised by the state supervision and the fiscal system as big taxpayers, banks do not have the possibility of tax evasion, for example through the transfer of profits abroad.

    The Polish Bank Association recognizes the right of state authorities to impose fiscal burdens that are designed to achieve the adopted economic policy of the country. However, the solution adopted in Poland is a very strong fiscal and is not used often globally due to its strong negative effects for banks and for the whole economy. The tax imposes burden in the same way for high and low risk banking activities. Unfortunately, authors of the legislative solution have not prepared any analysis of the impact the introduction of tax calculation of the estimated budget revenue from the tax.

    A strong additional fiscal burden on banks will result in a significant reduction in their profits, which in recent years in more than 80% were allocated to increase the banks' own funds. This allowed for the continuous expansion of lending, even in conditions of rising capital requirements imposed on banks by international prudential regulations.

    Banks, seeking to maintain the stability of the sector at a high level, will have to take action to adapt to new conditions. Special review will have to be subjected offering these services, which are characterized by low profitability. Some of them will probably have to be withdrawn from the offer of banks, another will have to be revised taking into consideration the pricing policy.

    It is already worth considering the changes in the tax burden of those institutions in the near future. This legal solution contains many provisions which raise serious doubts in interpretation. It is important to reduce the negative effects of the new tax as soon as possible.
    pobierz plik docx (0.162 MB)
  • PBA's Comments to the Commission’s Green Paper “Capital Markets Union” 13.05.2015 pobierz plik pdf (0.272 MB)
  • General remarks on the idea of Capital Markets Union (CMU) pobierz plik pdf (0.079 MB)
  • The Polish Bank Association comments on The EBA Consultation Document „Draft Guidelines on creditworthiness assessment„
    (as of December 12, 2014)
    pobierz plik pdf (0.041 MB)
  • The Polish Bank Association comments on The EBA Consultation Document „Draft Guidelines on arrears and foreclosure„
    (as of December 12, 2014)
    pobierz plik pdf (0.038 MB)
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