In the case of capital transformations in real estate companies, an important issue is the VAT treatment of certain transactions. The contribution of real estate to the company is considered a paid delivery of goods, and the consideration for this transaction are shares in the company.
This issue has been entrenched in tax practice for many years. Tax authorities and administrative courts agree that the taxable amount is the payment obtained by the contributor in return for a contribution in kind, and the amount of that payment is equivalent to the (gross) nominal value of the shares.
Source: www.mddp.pl
