The Management Board of P4 sp. z o.o. ("Play"), with reference to current report 11/2020 issued on November 30, 2020, informs that Play submitted corrective declarations for corporate income tax settlements for years 2015, 2016 and 2017. Those adjustments reflect the findings of the results of the customs and tax inspections delivered on December 17, 2020, concerning the above settlements led by the Head of the Masovian Customs and Tax Office in Warsaw.
As a result of the inspections, the authority recognized Play's settlements for license fees paid to the related entity, i.e. Play 3GNS spółka z ograniczoną odpowiedzialnością sp. k., as correct.
At the same time, the authority questioned the value of trademark depreciation write-offs included in Play's tax settlement, assuming that their initial value is determined by the lower limit indicated in the trademark appraisal report, prepared by an independent entity; and therefore, the partial deduction of depreciation write-offs for the relevant years in the amount of PLN 51 085 766.68 to PLN 51 195 720.52 was questioned.
In connection with the above, Play will pay to the account of the competent tax office the tax in the amount of PLN 19 424 466 plus PLN 6 570 849 of statutory interest.
The findings of the inspection authority for 2017 regarding the adoption of a lower value of trademarks as the basis for calculating depreciation have an impact on Play's tax liabilities in years 2018 and 2019 and will result in the payment of tax arrears in the total amount of at least PLN 9.8 million plus due tax interest.