Information on the implemented tax strategy for the tax year ended 31 March 2024.

Share on:

Table of contents

List of terms and abbreviations.
Introduction.
About the Company.
Processes and procedures in place to manage and ensure compliance with tax law obligations.
Voluntary forms of cooperation with the National Tax Administration authorities.
Information on tax obligations fulfilled by the Company in the territory of the Republic of Poland.
Information on the number of reports submitted to the Head of the National Fiscal Administration on the tax schemes referred to in Article 86a § 1(10) of the Tax Ordinance, broken down by the taxes to which they relate.
Information on transactions with related parties.
Information on restructuring activities planned or undertaken by the Company that may affect the tax liabilities of the Company or related parties.
Information on the taxpayer's tax settlements in territories or countries applying harmful tax competition.
Information on requests submitted by the Company.

1. List of terms and abbreviations

The following terms shall have the following meanings for the purposes of this document:

Company or DSSE: Daicel Safety Systems Europe sp. z o.o.;
Group: An international group led by Daicel Corporation, based in Japan;
Finance Department: A dedicated team established within the Company to handle, inter alia, tax settlements;
2023: The Company's tax year from 1 April 2023 to 31 March 2024;
CIT Act: Act of 15 February 1992 on Corporate Income Tax (consolidated text: Journal of Laws of 2023, item 2805, as amended);
Tax Ordinance: Act of 29 August 1997 on Tax Ordinance (consolidated text: Journal of Laws of 2023, item 2383, as amended);
PIT Act: Act of 26 July 1991 on Personal Income Tax (consolidated text: Journal of Laws of 2022, item 2647, as amended);
VAT Act: Act of 11 March 2004 on Tax on Goods and Services (consolidated text: Journal of Laws of 2023, item 1570, as amended);
Excise Duty Act: Act of 6 December 2008 on Excise Duty (consolidated text: Journal of Laws of 2023, item 1542, as amended);

2. Introduction

This document outlines the way in which DSSE will implemented its tax strategy in 2023.

As a corporate taxpayer with a turnover exceeding EUR 50 million achieved in the tax year ended 31 March 2024, the Company is required to draw up and publish information on its tax strategy implemented for 2023.

The purpose of this information is for the Company to fulfil its obligations under Article 27c of the CIT Act to draw up and make public information on its tax strategy for a tax year. By publishing information on the tax strategy that we implement, we intend to improve the tax transparency of taxpayers playing a significant role in the Polish market and to foster public trust.

At the same time, this information does not pertain to data to which access is restricted based on applicable laws in this respect, in particular information covered by regulations on the protection of classified information.

Furthermore, this document excludes confidential information which, considering the Company's business plans and undertakings, is protected as data subject to trade, industrial, business or manufacturing secrecy.

3. About the Company

DSSE is part of Daicel Corporation Ltd. of Japan, established in 1919.

The company manufactures inflators intended for automotive airbags to meet the demands of the market for driver and passenger protection. The corporation provides products of high quality and offers the highest standard of customer service.

With an eye on the demands of today's automotive market, DSSE manufactures inflators for various types of airbags (driver, passenger, side curtain and other).

Basic information about the Company

Name: Daicel Safety Systems Europe Spółka z ograniczoną odpowiedzialnością
Registered office: ul. Strefowa 6, 58-130 Żarów
Identification details:

KRS No. (National Court Register): 0000200661
NIP (Tax ID ): 8862753552
REGON (Business ID): 891525310
BDO (Waste Database): 000088578

Amount of the share capital: PLN 5,000,000.00
Date of entry in the Register of Entrepreneurs of the National Court Register: 22 March 2004.

4. Processes and procedures in place to manage and ensure compliance with tax law obligations

The basic rules for handling tax cases relied mainly on the law and generally accepted tax practices.

Tax settlements

In its operations, the Company remained committed to accurate reporting and compliance, including the on-time submission of all tax returns, forms and information and meeting tax payment deadlines. The Company took great care to ensure that the information provided faithfully reflected the facts and was complete, up-to-date and understandable.

In order to ensure the correctness of the tax accounts, it was vital for the Company to employ competent staff, as the persons who implemented the Company's tax function in practice were those employed at DSSE. The Finance Department's staff performing tax settlement activities for the Company were expected to exercise due diligence in performing their duties and to ensure that all decisions related to tax settlements were based on properly maintained records. Furthermore, they had the necessary knowledge and skills in order to ensure that the Company's obligations under tax law were properly implemented, in particular they kept track of changes in tax law and the decisions of tax authorities and administrative courts.

The company took measures aimed at minimising tax risks and disputes with tax authorities. While preparing the tax settlements, the Finance Department exercised professional judgement and strove to update its know-how.

Furthermore, in selected areas, points raising doubts were also consulted with external tax advisors and others.

Information management and recording

With a view to ensuring the correct and complete recording of data collected, the Company is equipped with IT tools, including, in particular, an extensive accounting system enabling the continuous integrity of the data entered and work automation. The IT solutions introduced by the Company for the tax function guarantee that tax returns and financial statements are correctly prepared and filled out, that tax is calculated and that tax payments are managed.

The Company takes care to protect information and data by securing the necessary resources against unauthorised use. The data and information collected are regularly archived.

5. Voluntary forms of cooperation with the National Tax Administration authorities

In the course of 2023, the Company did not use any voluntary forms of cooperation with the National Tax Administration authorities as defined in Article 27c(2)(1)(b) of the CIT Act.

6. Information on tax obligations fulfilled by the Company in the territory of the Republic of Poland

In 2023, the Company took the necessary steps to fulfil its obligations under the tax law in the territory of the Republic of Poland in a correct and timely manner; in particular, the Company took great care to ensure reliable reporting, submit all returns and forms on time, collect documentation and meet tax payment deadlines. The Company took great care to ensure that the information provided faithfully reflected the facts and was complete, up-to-date and understandable.

The main taxes for which the Company fulfilled its obligations were corporate income tax, value added tax and property tax.

In addition, in 2023, the Company paid a product fee, a fee for releasing gases or particulates into the air and a duty. It also performed its obligations as a payer of withholding tax, personal income tax and social and health insurance on salaries and wages paid to the Company's staff.

7. Information on the number of reports submitted to the Head of the National Fiscal Administration on the tax schemes referred to in Article 86a § 1(10) of the Tax Ordinance, broken down by the taxes to which they relate

The Company analysed the transactions or activities performed, bearing in mind the existence of an obligation to report information on tax schemes.

In 2023, the Company did not identify any activities or transactions that, under Article 27c(2)(2) of the CIT Act, would require it to provide information on tax schemes to the National Tax Administration.

8. Information on transactions with related parties

In 2023, the Company executed the following transactions with related parties (as defined in Article 11a(1)(14) of the CIT Act), the value of which exceeded 5% of total assets as defined in the accounting regulations, determined according to the Company's last approved financial statements:

sales of finished goods to entities in Japan, the United States, India and the People's Republic of China,
purchase of manufacturing materials from entities in Japan and Thailand,
purchase of import sales from entitie the People's Republic of China,

The Company fulfilled its transfer pricing obligations in a timely manner and, in particular, holds transfer pricing documentation for 2023. In addition, the Company filed its transfer pricing information (Form TPR-C) on time.

9. Information on restructuring activities planned or undertaken by the Company that may affect the tax liabilities of the Company or related parties

In 2023, the Company did not undertake or plan to undertake any restructuring activities that could affect the tax liabilities of the Company and its related parties as defined in Article 11a(1)(4) of the CIT Act.

10. Information on the taxpayer's tax settlements in territories or countries applying harmful tax competition

The Company did not make any tax settlements in the territories or countries applying harmful tax competition as indicated in the executive acts issued pursuant to Article 11j(2) of the CIT Act and pursuant to Article 23v(2) of the PIT Act and in the notice of the minister in charge of public finance issued pursuant to Article 86a § 10 of the Tax Ordinance.

In particular, in 2023, in the aforementioned territories/countries, the Company:

was not registered for tax purposes,
did not submit tax returns or forms,
did not collect and pay taxes.

11. Information on requests submitted by the Company

In 2023, the DSSE did not submit any requests for:

an individual interpretation of tax regulations referred to in Article 14b of the Tax Ordinance,
a general interpretation of tax regulations referred to in Article 14a § 1 of the Tax Ordinance,
binding rate information referred to in Article 42a of the VAT Act,
binding excise information referred to in Article 7d(1) of the Excise Duty Act.