The purpose of preparing the information is to fulfill the obligations imposed on SNS FOODS Spółka z ograniczoną odpowiedzialnością, resulting from art. 27c section 1 of the Corporate Income Tax Act of 15 February 1992 (Journal of Laws 2023, item 2805, as amended, hereinafter referred to as: CIT Act) regarding the preparation and public disclosure of information on the implemented tax strategy for the tax year.
The information was prepared for the Company's tax year from January 1, 2023 to December 31, 2023. The information does not contain information that is proprietary due to applicable legal provisions and does not include confidential information that, due to ongoing or planned business activities, is covered by trade, professional or production process secrets.
COMPANY INFORMATION
SNS FOODS Spółka z ograniczoną odpowiedzialnością (hereinafter referred to as the Company) with its registered office and place of management in Poland, 90-032 Łódź, ul. Kopcińskiego 69/71, NIP: 9471857420, REGON: 472350036, BDO No.: 000034507, entered into the National Court Register, maintained by the District Court for Łódź Śródmieście in Łódź, XX Division of the National Court Register, under KRS number: 0000185194.
The Company was established by a notarial deed of 29 May 2000 under the name Matex Sp. z o.o. On 28 August 2006, a notarial deed changed the current profile of activity and changed the name to SNS Trading Sp. z o.o. By a notarial deed of 29 November 2013, the Extraordinary General Meeting of Shareholders resolved to amend the Company's agreement, according to which the Company conducts business under the name SNS FOODS Spółka z ograniczoną odpowiedzialnością. The change of the Company's name was entered into the National Court Register on 2 January 2014. The Company's main business is wholesale trade in meat and meat products. In the Company, the tax year coincides with the calendar year. The Company is an active taxpayer of the goods and services tax.
SNS FOODS Spółka z o.o. forms a Capital Group with Snowman Foods Solution Spółka z ograniczoną odpowiedzialnością, in which SNS FOODS is the parent entity and Snowman Foods Solution is a subsidiary. As of 31.12.2023, SNS FOODS Spółka z o.o. held 80% of the shares in the Subsidiary. The cooperation of both companies is aimed at strengthening the market position and increasing development opportunities.
The mission of SNS FOODS Sp. z o.o. is "Let's develop and grow safely together". We base our activities on 4 pillars of values:
• Ethics
• Development and achievement
• Respect for people
• Quality of products and services
The indicated principles, which are included in the Company's operating strategy, also translate into the area of public law obligations. The Company's fundamental goal is to comply with the applicable provisions of tax law, reliability, correctness, transparency and timeliness in fulfilling tax obligations and settling taxes. The Company ensures correct and timely fulfillment of the obligations imposed by tax law, verifies the tax consequences of its business decisions and does not undertake tax-risky activities and minimizes the risk of potential disputes with tax authorities.
INFORMATION ABOUT THE PROCESSES AND PROCEDURES USED BY THE TAXPAYER FOR MANAGING THE PERFORMANCE OF OBLIGATIONS ARISING FROM THE PROVISIONS OF TAX LAW AND ENSURING THEIR CORRECT PERFORMANCE.
The processes and procedures for managing the performance of obligations resulting from tax law regulations and ensuring their correct performance used in the Company include:
• implemented instructions and procedures, including document circulation and acceptance of invoices, control of documents and accounting documents, control of timeliness and correctness of tax returns, tax payments, division of roles and responsibilities,
• maintaining accounting books and tax records in accordance with the regulations of the Accounting Act and the guidelines of the National Accounting Standards issued by the Accounting Standards Committee, as well as tax acts and their implementing regulations,
• managing tax risk by taking actions that could reasonably be expected from the Company to identify that the transaction was not carried out with abuse or fraud, including:
- verifying contractors, including checking contractors in the VIES, KRS or CEiDG systems,
- checking whether the contractor is registered as an active VAT payer on the date of the transaction,
- checking whether the bank accounts assigned to the contractor are on the "white list",
- checking whether the data on the invoice has been correctly completed address, name and Tax Identification Number, checking the application of mandatory split payment,
- informing the relevant Tax Office in the event of a payment being made to a bank account that is not on the “white list”,
- cooperation with banks servicing the Company in the scope of verification of contractors in terms of counteracting money laundering and terrorism financing,
• archiving data and documents.
In the event of unusual transactions or complex changes in tax regulations, the Company uses available publications and online databases containing tax interpretations.
The principles of operation of the Company, including the organizational structure, are aimed at timely and reliable fulfillment of the obligations arising from the provisions of tax law by the Company in the field of taxes and tax settlements, accounting, human resources and payroll.
Accounting, HR and payroll functions as well as tax processes are performed by employees with the knowledge and competence to perform the tasks assigned to them in these areas. Employees use industry services and monitor changes in tax law. They have the opportunity to use training to update their knowledge and improve their professional qualifications. In doubtful situations, employees responsible for the proper implementation of tax obligations cooperate with external companies specializing in tax consulting.
INFORMATION ON VOLUNTARY FORMS OF COOPERATION USED BY THE TAXPAYER WITH THE NATIONAL FISCAL ADMINISTRATION AUTHORITIES
The Company did not undertake any formal voluntary forms of cooperation with the National Revenue Administration bodies during the tax year. The Company bases its relations with the National Revenue Administration bodies on openness, transparency and willingness to cooperate. The Company responds to all calls, questions or requests from the tax authorities in a timely manner and provides appropriate explanations to the best of its knowledge and the required information, in accordance with the applicable provisions of law in this area.
INFORMATION ON THE TAXPAYER'S FULFILLMENT OF TAX OBLIGATIONS IN THE TERRITORY OF THE REPUBLIC OF POLAND, TOGETHER WITH INFORMATION ON THE NUMBER OF INFORMATION ON TAX SCHEMES PROVIDED TO THE HEAD OF THE NATIONAL FISCAL ADMINISTRATION, REFERRED TO IN Article 86a § 1 item 10 OF THE TAX ORDINATION, DIVISIONED INTO TAXES TO WHICH THEY CONCERN
The Company takes the necessary measures and makes every effort to properly and timely fulfill the tax obligations imposed on the Company by, among others:
• identifying events that give rise to tax liability,
• timely submission of tax returns, information and reports required by tax law,
• preparing and sending JPK_V7M files,
• determining and timely payment of taxes due,
• correct recording of fixed assets and intangible assets,
• preparing transfer pricing documentation together with TPR-C tax information.
During the tax year, the Company fulfilled tax obligations as a taxpayer in respect of the following taxes:
• corporate income tax (CIT),
• goods and services tax (VAT),
• real estate tax,
• civil law transactions tax.
During the tax year, the Company fulfilled tax obligations as a payer in respect of the following taxes:
• personal income tax (PIT),
During the tax year, the Company did not identify any arrangements that met the definition of a tax scheme and, consequently, did not provide the Head of the National Revenue Administration with information on tax schemes.
INFORMATION ON TRANSACTIONS WITH RELATED ENTITIES WITHIN THE MEANING OF ART. 11a sec. 1 item 4, WHOSE VALUE EXCEEDS 5% OF THE BALANCE SHEET ASSETS TOTAL WITHIN THE MEANING OF ACCOUNTING REGULATIONS, ESTABLISHED ON THE BASIS OF THE LAST APPROVED FINANCIAL STATEMENTS OF THE COMPANY, INCLUDING ENTITIES THAT ARE NOT TAX RESIDENTS OF THE REPUBLIC OF POLAND
In the tax year, the sum of the value of transactions conducted by the Company with related entities exceeded 5% of the balance sheet total assets resulting from the Company’s financial statements for the year from January 1, 2023 to December 31, 2023.
According to the Company's financial statements for 2023, the balance sheet total of assets amounted to PLN 63,115,655.20, while 5% of this amount is PLN 3,155,782.76.
Transactions with related entities within the meaning of Article 11a section 1 item 4, the value of which exceeds 5% of the balance sheet total of assets concerned:
• purchase of storage, packaging, stacking, confectioning services, etc.
• granting of loans
• granting of guarantees
In 2023, the Company did not enter into controlled transactions of a homogeneous nature with related entities that are not tax residents in Poland with a value calculated separately for each transaction exceeding 5% of the balance sheet total of assets. The Company prepares transfer pricing documentation with related entities along with tax information TPR-C.
INFORMATION ON RESTRUCTURING ACTIONS PLANNED OR UNDERTAKEN BY THE TAXPAYER WHICH MAY HAVE AN IMPACT ON THE AMOUNT OF TAX LIABILITIES OF THE TAXPAYER OR RELATED ENTITIES WITHIN THE MEANING OF Art. 11a sec. 1 item 4
In May 2023, the Company acquired shares of an associated company.
In the 2023 tax year, the Company did not undertake any other restructuring activities that could affect the amount of tax liabilities of the Company or its related entities within the meaning of Art. 11a sec. 1 item 4 of the CIT Act.
At the beginning of 2025, a merger by acquisition is planned between SNS FOODS Sp. z o.o. as the acquiring company and Snowman Foods Solution Sp. z o.o. as the acquired company.
INFORMATION ON APPLICATIONS SUBMITTED BY THE TAXPAYER. APPLICATIONS FOR THE ISSUANCE OF A GENERAL TAX INTERPRETATION REFERRED TO IN ART. 14a § 1 OF THE TAX ORDINATION
During the tax year, the Company did not apply for a general tax interpretation, as referred to in Art. 14a § 1 of the Tax Ordinance.
APPLICATIONS FOR THE ISSUANCE OF AN INTERPRETATION OF TAX LAW PROVISIONS REFERRED TO IN ARTICLE 14b OF THE TAX ORDINATION
During the tax year, the Company did not apply to the National Tax Information for an individual interpretation of tax law provisions, as referred to in Art. 14b of the Tax Ordinance in the scope of goods and services tax.
APPLICATIONS FOR THE ISSUANCE OF BINDING RATE INFORMATION REFERRED TO IN ARTICLE 42a OF THE ACT ON GOODS AND SERVICES TAX
During the tax year, the Company did not apply for the issuance of binding rate information referred to in Art. 42a of the Goods and Services Tax Act.
APPLICATIONS FOR THE ISSUANCE OF BINDING EXCISE INFORMATION REFERRED TO IN Article 7d section 1 of the EXCISE DUTY ACT
During the tax year, the Company did not apply for the issuance of binding excise information referred to in Art. 7d sec. 1 of the Excise Duty Act.
INFORMATION ON MAKING TAX SETTLEMENTS OF A TAXPAYER IN TERRITORIES OR COUNTRIES APPLYING HARMFUL TAX COMPETITION
During the tax year, the Company did not make any tax settlements in territories or countries applying harmful tax competition, indicated in the implementing acts issued under Article 11j paragraph 2 and under Article 23v paragraph 2 of the Personal Income Tax Act of 26 July 1991 and in the announcement of the minister responsible for public finances issued under Article 86a § 10 of the Tax Ordinance, and was not registered for tax purposes in any of these territories or countries.
In 2023, the Company entered into transactions with unrelated entities based in Hong Kong, Mauritius and Curacao as part of the sale of commercial goods.
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