Information on the executed tax strategy
for 2022

Nielsen Services Poland Spółka z ograniczoną odpowiedzialnością

 Prepared: 4 December 2023

List of terms and abbreviations 

For the purposes of this document, the following terms were given the following meanings: 

1.  Introduction and legal basis

This document provides information on the tax strategy executed in 2022 by Nielsen Services Poland Spółka z ograniczoną odpowiedzialnością.

The Company, as a taxpayer of Corporate Income Tax with a turnover exceeding EUR 50 million earned in the fiscal (tax) year ending 31 December 2022, is required to prepare and publish information on the executed tax strategy executed for the fiscal (tax) year ending 31 December 2022. This Information has been prepared in order to comply with the obligation set out in Article 27c(1) in connection with Article 27b(2)(1) and (2) of the CIT Act. The contents of the Information should be interpreted in the context of the regulations constituting the basis for its preparation.

Any data that is subject to commercial, industrial, professional or manufacturing process secrecy and information to which is restricted due to applicable laws or contractual obligations, as well as data related to specific business decisions planned or made by the Company may have been excluded from the publication.

2.  Nielsen Services Poland – basic information

Nielsen Services Poland Spółka z ograniczoną odpowiedzialnością is a data processing and comprehensive market research company, providing services for other NielsenIQ Group entities.

3.  Tax processes and procedures

Legal basis: Pursuant to Article 27c(2)(1)(a) of the CIT Act, the taxpayer shall provide information on the processes and procedures for managing and ensuring the proper fulfilment of its obligations under tax law.

Nielsen has appropriate tax resources, tools and procedures that have been developed and implemented with consideration of the individual Company profile, its organisational structure and the specific industry in which it 4 

operates. These are designed to effectively manage and correctly fulfil tax obligations under the applicable tax legislation. 

The Company’s basic principles for handling tax matters were based on tax legislation and generally accepted best practices in the field of tax. The Company aimed to properly manage, control and settle taxes, enabling it to properly and timely fulfil its tax obligations and meet its tax reporting requirements in 2022. 

The Company monitors and, where necessary, improves its tax processes in order to properly identify and then fulfil its tax obligations in a correct and timely manner. 

While analysing the proper fulfilment of the Company’s tax obligations, the regulations of the NielsenIQ Group, of which the Company is a subsidiary, must also be considered. These oblige all Group companies, as well as the Group’s business partners, to conduct business in an ethical and balanced manner. The above concerns also the fulfilment of tax obligations. Examples of documents providing these regulations include, in particular: 

• The Nielsen Code of Conduct, which defines the Group’s business principles, indicating that business must be conducted in accordance with the law and the highest ethical standards; 
• Nielsen’s Supplier Code of Conduct, which is the Group’s current standard promoting responsibility among stakeholders and which encourages the implementation of responsible practices among its suppliers. 

The Group also published an ESG Report which presented the key data and information on corporate social responsibility-related issues. The report also provided the principles of managing the Group’s business in a balanced way by integrating social, environmental and ethical aspects into its operations. 

The fulfilment of the Company’s tax obligations was carried out by experienced, highly qualified employees with many years of work experience in the Company. This ensures the compliance of the Company’s tax settlements with the regulations – not only through the implementation of stable and reliable processes, but also by the highest diligence exercised by the aforementioned employees. 

In order to fulfil its tax obligations, the Company has used the support of external tax advisors from independent and esteemed advisory firms. The tax support services have been carried out in accordance with the highest standards and in a comprehensive manner. In addition, the Company’s tax processes were also partially supported by the Group’s tax specialists. 

Regarding risk management and control, the Company took measures to identify tax risks through appropriate monitoring and mitigation mechanisms, and subsequently eliminated them or reduced their impact on its operations. Furthermore, in order to ensure the correctness of the decisions made on specific tax matters requiring consultation, the level of risk associated with these decisions was assessed on the basis of the support and information provided by the relevant Group entities. 

At the same time, in order to ensure the correct and complete recording of the collected data, the Company utilised appropriate IT tools to maintain the integrity of the data and to partially automate relevant processes. The IT tools used by the Company were adapted to the current needs, corresponding to the business and the industry in which it operates, and allowed for the correct preparation and filing of tax returns, as well as for fulfilment of other statutory obligations in a transparent and comprehensive way. 

4.  Information on the fulfilled tax obligations

Legal basis: Pursuant to Article 27c(2)(1)(a) of the CIT Act, the taxpayer shall provide information on the processes and procedures for managing and ensuring the proper performance of its obligations under tax law.

In its business activities, the Company focuses on diligent reporting and compliance, including the timely filing of all tax returns, forms and information, the collection of relevant documentation and making appropriate tax payments on time. Accordingly, the Company strives to ensure that the information provided in relation to its tax obligations clearly and accurately reflects the facts and that it is complete, clear and up-to-date. 

In 2022 Nielsen carried out tax obligations in all areas required by the tax law, in terms of: 

• Corporate Income Tax (CIT), 
• Withholding Tax (WHT), 
• Value Added Tax (VAT), 
• Personal Income Tax (PIT), 
• Social security contributions on salaries paid to its employees (ZUS). 

The Company also settled liabilities stemming from the Tax on Civil Law Transactions (PCC). 

The Company’s data as a CIT taxpayer regarding the assessment of CIT tax liabilities are regularly published pursuant to Article 27b(2) of the CIT Act on the website of the Ministry of Finance¹. 

^[1] https://www.gov.pl/web/finanse/indywidualne-dane-podatnikow-cit

5.  Voluntary forms of cooperation with the National Revenue Administration

Legal basis: Pursuant to Article 27c(2)(1)(b) of the CIT Act, the taxpayer provides information on voluntary forms of cooperation with the National Revenue Administration authorities

In 2022, the Company did not participate in any voluntary forms of cooperation with the authorities of the National Revenue Administration within the meaning of Article 27c(2)(1)(b) of the CIT Act, in particular the Company does not participate in the Cooperative Tax Compliance Programme implemented by the Ministry of Finance.

6.   Tax schemes

Legal basis: Pursuant to Article 27c(2)(2) of the CIT Act, the taxpayer provides information on the taxpayer’s fulfilment of tax obligations on the territory of the Republic of Poland, together with information on the number of information on tax schemes referred to in Article 86a(1)(10) of the Tax Ordinance, by tax to which they relate, provided to the Head of the National Revenue Administration.

In 2022 the Company has verified that certain occurrences do not result in a tax scheme reporting obligation and has not identified any occurrences that would be reportable as a tax scheme. Accordingly, in 2022 the Company did not report any information on tax schemes to the Head of the National Revenue Information pursuant to Article 27c(2)(2) of the CIT Act.

In addition, the Company regularly reviews relevant economic events in terms of generating an obligation to report on tax schemes. An appropriate procedure in this regard has been implemented as well.

7.  Transactions with related entities

Legal basis: Pursuant to Article 27c(2)(3)(a) of the CIT Act, taxpayers provide information on transactions with related entities, within the meaning of Article 11a(1)(4) of the CIT Act, whose value exceeds 5% of total assets within the meaning of the accounting regulations, determined on the basis of the company’s last approved financial statements, including entities that are not tax residents of the Republic of Poland.

The Company carried out the following transactions with related entities within the meaning of Article 11a(1)(4) of the CIT Act in 2022, the value of which exceeded 5% of total assets:

•  Sales to an entity based in Switzerland²

The Company complied with its transfer pricing obligations on time. In accordance with the applicable regulations, the Company verified the transactions subject to the documentation obligation for the previous tax year and prepared the Local File with the relevant comparative analyses. The Company’s settlements with related entities in 2022 were made in accordance with the arm’s length principle.

^[2] 5% of the total assets value in 2022 amounted to PLN 6 164 150

8.  Restructuring activities 

Legal basis: Pursuant to Article 27c(2)(3)(b), taxpayers shall provide information on restructuring activities planned or undertaken by the taxpayer which may affect the amount of tax liabilities of the taxpayer or of related entities within the meaning of Article 11a(1)(4) of the CIT Act.

In 2022, the Company did not undertake any restructuring activities that could affect the tax liabilities of the Company or its related entities within the meaning of Article 11a(1)(4) of the CIT Act, and did not plan to undertake such activities in the future.

In 2022, efforts were in progress to merge the NielsenIQ Group, to which the Company belongs, with the Gfk Group. Detailed information in this regard is available on the Group’s website.

9.  Tax settlements in territories or countries applying harmful tax competition

Legal basis: Pursuant to Article 27c(2)(5) of the CIT Act, taxpayers provide information on the tax settlements of the taxpayer in territories or countries applying harmful tax competition indicated in executive acts issued on the basis of Article 11j(2) of the CIT Act and on the basis of Article 23v(2) of the PIT Act and in the announcement of the minister competent for public finance issued on the basis of Article 86a § 10 of the Tax Ordinance.

In 2022, the Company did not make tax settlements in the territories or countries applying harmful tax competition indicated in the executive acts issued pursuant to Article 11j(2) and pursuant to Article 23v(2) of the Personal Income Tax Act of 26 July 1991 and in the announcement of the Minister competent for public finance issued pursuant to Article 86a § 10 of the Tax Ordinance.

In particular, in 2022, in the territories/countries indicated above, the Company:

• was not registered to settle taxes;
• did not file tax returns or forms;
• did not collect and remit taxes, including withholding tax.

10.  Submitted applications

Legal basis: Pursuant to Article 27c(2)(4) of the CIT Act, taxpayers shall provide information on applications submitted for the issuance of:

a) general tax interpretation referred to in Article 14a § 1 of the Tax Ordinance,

b) tax law interpretations referred to in Art. 14b of the Tax Ordinance,

c) binding tax rate information referred to in Art. 42a of the Value Added Tax Act,

d) binding excise duty information referred to in Article 7d(1) of the Excise Duty Act.

In 2022, the Company did not submit applications for:

• an individual tax ruling within the meaning of Article 14b of the Tax Ordinance;
• a general tax ruling within the meaning of Article 14a § 1 of the Tax Ordinance;
• binding tax rate information within the meaning of Article 42a of the VAT Act;
• binding excise duty information within the meaning of Article 7d (1) of the Excise Duty Act.