- The text is a letter from the Director of the National Tax Information regarding the incorrect tax assessment of the sale of perpetual usufruct rights to a property.
- The letter states that the taxpayer’s position on the tax consequences of the described factual situation is incorrect.
- The taxpayer had submitted a request for an individual interpretation of the tax implications of selling perpetual usufruct rights to a property.
- The letter provides a description of the factual situation, including the sale of the property to the current perpetual usufructuary and the previous transfers of perpetual usufruct rights.
- The letter mentions that the property is not located in a degraded or revitalization area according to the resolutions of the Municipal Council.
- The letter refers to a judgment of the Court of Justice stating that the transformation of perpetual usufruct rights into ownership rights is a separate taxable transaction and not a continuation of the previous transaction of granting perpetual usufruct rights.
Source: sip.lex.pl
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.
