The new PGK will be exempt from minimum tax
A Tax Group of Companies (PGK) will be exempt from paying the minimum tax in the first two years.
According to the tax authorities’ interpretation, PGKs that are start-ups in a given tax year and in the two tax years immediately following that year will benefit from the exemption from paying the minimum tax, pursuant to Article 24ca(14)(1) of the CIT Act.
It is also worth mentioning that a new PGK may not choose the quarterly system of paying advance payments of corporate income tax in the first and second year of operation.
The PGK, as a newly established entity, will not be entitled to use the simplified form of paying advance payments for corporate income tax in the first and second year of its operations, in accordance with the applicable tax law and court rulings.
Interpretation of the Director of the National Fiscal Information dated 4 January 2024, No. 0111-KDIB1-2.4010.612.2023.2.END.