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    ZPP survey: 95% of “platform workers” are satisfied with the cooperation with the platforms. Most of them are against compulsory employment contracts.

    Posted on by Weronika Marzec

    Warsaw, 5 May 2022

     

    ZPP survey: 95% of “platform workers” are satisfied with the cooperation with the platforms. Most of them are against compulsory employment contracts.

     

    The survey was conducted in early 2022. The quantitative part was carried out using the CATI method, while the qualitative part in turn was developed on the basis of individual in-depth interviews. The survey included “platform workers” representing the following sectors:

    – food delivery,

    – passenger transport,

    – repairs and small services,

    – childcare,

    – parcel delivery,

    – IT services

    ADVANTAGES OF PLATFORM WORK ACCORDING TO EMPLOYEES

    According to the survey, one of the main factors encouraging people to work with platforms is the possibility of easier and faster access to customers or a low entry threshold, i.e. the ability to start work easily.

    A high level of flexibility is also important for “platform workers”. The fact that these expectations are realized in cooperation with platforms is evidenced by the fact that the same factors were indicated by the interviewees as key advantages of cooperation with platforms. As a result, 95% of respondents say they are satisfied with working with the platform.

    Respondents assess the terms of cooperation with platforms as understandable (98%) and fair (96%). The level of satisfaction with the cooperation, as well as a positive assessment of its conditions, also translates into an assessment of their own financial situation. 93% of “platform workers” assess their financial situation well, and almost every third respondent earns an income of more than 5 thousand PLN net from orders received through the platform.

    The high level of satisfaction with the cooperation with the platforms and the conditions they offer is reflected in the professional plans of the respondents. More than 80% of them plan to work in this type of job for longer, either as the only (42%) or additional (41%) source of income. For only 17% of respondents, “platform work” is temporary and temporary in nature.

    Significantly, but also very consistent with the responses to the question about the greatest advantages of “platform work,” the majority (61%) of platform collaborators surveyed would not want to see a law enacted that would make it necessary for the platform to hire them on a full-time basis, with 24% strongly opposing such an idea. At the same time, more than 40% would be willing to give up some of the pay or flexibility of the collaboration to gain the rights granted by the labor law.

    Thus, it should be considered that “platform workers” are in favor of freedom in shaping the relationship between themselves and the platforms. The vast majority of platform workers are self-employed, but 14% work under an employment contract. This suggests that there are different models of cooperation between platform workers and platforms.

    It seems important that almost ¾ of the respondents (and most of the respondents have more than two years of experience working with platforms) have never encountered inconveniences when working with platforms. One in five respondents stated that they occasionally noted such inconveniences, generally in the nature of technical problems or application crashes. In the qualitative interviews, “platform workers” highlighted their perceived weaknesses in working with platforms. As a rule, they were related to specific rules resulting from the regulations of the platform, e.g. relating to commissions charged or settlement rules.  

    ZPP’s contribution to the Commission’s consultation on the VAT in a digital age

    Posted on by Weronika Marzec

    Warsaw, 9 May 2022

     

    ZPP’s contribution to the Commission’s consultation on the VAT in a digital age

     

    The Union of Entrepreneurs and Employers (ZPP) is pleased to participate in the public consultation on the “VAT in the Digital Age” proposal announced by the European Commission. Beyond responses provided in the survey, we would like to comment particularly on Single EU VAT Registration and Import One Stop Shop (IOSS) development workstreams. Additionally, we would like to draw attention to the current functioning of the Union One Stop Shop (UOSS) & IOSS. We will focus on how these mechanisms can be modified to serve their purpose better. IOSS & UOSS have experienced changes in their functioning following the e-commerce VAT package. The introduction of both processes has undoubtedly simplified VAT registration and accounting. Nevertheless, together with our members, we have identified certain issues that do not provide legal certainty for enterprises and can lead to loopholes in law application.

    Firstly, we find the functioning of the multiple OSS registrations redundant. Non-EU entities might, under currently functioning VAT rules following the go-live of the e-commerce VAT package, establish three different registrations for fulfilling EU VAT obligations; these are Non-Union OSS, UOSS and IOSS. In our view, this creates unnecessary complexity for companies. For this reason, we state that it would be beneficial to integrate these different schemes so that all types of supplies can be declared through One Stop Shop, including imported goods, services and domestic sales.

    Secondly, entrepreneurs find it troublesome to report credit notes and adjustments on product returns, invoicing errors and post-invoicing discounts. Current regulations require adjustment to be divided by country and period. This causes avoidable burdens for companies to fulfil their tax duties. In practice, this results in burdensome reporting obligations of the credit notes, which might take longer to process than to put together the return reporting tax due. We recommend easing the responsibility to split credit by period, thus making the One Stop Shop return efficient.

    Import One Stop Shop (IOSS)

    We welcome improvements brought with the implementation of the IOSS, such as the introduction of VAT calculation and remittance upon sale. Nevertheless, we would like to address issues that remain obstacles for companies under the current legal order.

    First of all, we would like to draw attention to the double taxation issue. IT taxation systems in some of the EU Member States are not yet ready to implement the functioning of the IOSS. As a result, H1 customs declarations of the IOSS-eligible shipments do not recognise IOSS identification codes and might lead to the double taxation of the companies.

    EU has done much to implement the mechanism to support double tax refunds. Nonetheless, this should only come as a temporary solution and shall be replaced with a widely functioning IOSS system across the EU. This is because double taxation causes administrative burdens for entities obliged to declare tax. Moreover, taxpayers might pose sanctions resulting from the lack of complementarity in functioning H1 customs declarations at the EU level. Therefore, IOSS numbers should become recognised by IT systems across all EU Member States to harmonise the execution of the regulations and ultimately simplify the functioning of the cross-border enterprises.

    Another factor causing inconveniences for the operation of European entrepreneurs is the potential misuse of IOSS numbers. Under currently biding regulations, it might occur that the IOSS number will be intentionally used inappropriately as well as misused by mistake—currently, IOSS is an optional feature. Additionally, numbers are not kept confidential, and there is no transparency among IOSS holders. That is why customs authorities can’t verify the actual holder of the number or payment of the VAT consignment but only whether the number is valid. The above factors contribute to the increased possibility of IOSS numbers misuse to avoid paying VAT at the customs border. For that reason, IOSS accounting is more frequently controlled, which might cause additional burdens for companies. IOSS registrant will have to explain reconciling differences between EU customs data and IOSS returns. This involves proving why they are not responsible for the IOSS misuse.

    Finally, in the EU, there are existing disparities between customs legislation and EU VAT. It is evident in the example of non-IOSS eligible shipments under EUR 150, such as B2B and excisable products, requiring direct clearance in the final delivery country under the scope of VAT and the new customs competent office rule emphasised in Article 212(4) of the UCC/IA.

    In our opinion, the functioning of IOSS and UOSS should be strengthened in order to make taxpayers’ obligations harmonised across the EU and thus ease the fulfilment of their obligations and remove the existing barriers to doing business.

    Proposals to improve the functioning of UOSS and IOSS

    The Union One Stop Shop has been enforced with the beginning of July 2021. It brought the simplification to the VAT settlement process for entrepreneurs. IOSS also forms a base for EU single VAT registration. Based on our expertise and experience shared by our members, we recommend UOSS extension to include usage in cases that were included in the e-commerce VAT package reform from July 1, 2021. We suggest covering with its scope reporting intra-EU transfers of own inventory as well as reporting and payment of VAT due on any onward B2C sale from the place of storage to the local customer. With this, we aim to remove local registration responsibilities for entities without a local establishment to conduct these transactions. We state that the UOSS serving domestic sales by non-established entities will have a positive impact unless a harmonised EU-wide domestic reverse charge mechanism is introduced whereby the customer self-accounts for the VAT due on its purchase. In our opinion, it would be beneficial to prevent registration obligations in the same way both B2B sales and B2C supplies. Often, enterprises will trade with their contractors, not knowing their actual business status at the time of the sale. For this reason, a reform introducing changes to B2C supplies would eradicate many additional VAT registration burdens for the EU industry and empower cross-border trade.

    Harmonising VAT registration through its standardising would enable the lifting of administrative requirements. It would fully enrich European entrepreneurs’ potential and minimise avoidable barriers for tax authorities, governments, and customs services. Hence, it will benefit both the administration and the private sector, which should be a primary aim of the regulation. For national governments, this means creating a more competitive EU market, which would lead to the intensification of trade, thus increasing tax revenues. At the same time, tax authorities will benefit from simplified and compliant reporting procedures and easier facilitation of cross-border goods movements. As a result, there will increase in the on-shore of goods and services on the internal market.

    On the other hand, the influx of individual packet shipments from non-EU countries will be reduced due to onward incentive distribution within the block. This will reduce the workload of customs services as they will receive more bulk shipments than individual ones. It means better access to the internal market and increased trade for the private sector. SMEs will benefit from lesser tax obligations; thus, they will be more competitive. Last but not least, customers will have a wider choice of products at more competitive prices, which will be delivered faster.

    Extention of the UOSS to all B2B and B2C sales is beneficial and relatively easy to carry out in our stance. Alternatively, we envisage the possibility of implementing a domestic reverse charge for B2B supplies to locally VAT registered companies across the EU. Equally important is to reinforce the mechanism over the transfer of goods. We note that the efficient system for cross-border transfer of goods would benefit the lessors of consignment stock sellers, e-mobility providers, agricultural producers, touring events companies, moveable property, customers of toll manufacturers, retailers & wholesalers using remote fulfilment, as well as companies involved in sale-or-return contracts.

    Current regulations make the VAT recoverable by entities through their local VAT registration in the country of arrival. This results from the fact that the cross-border transfer triggers a VAT charge but no cash flow or associated cost. On the other hand, the cash flow to the input side of transfers of own goods in UOSS might not be easy as is the case for the output side. Currently, there is no possibility of recovering VAT in the UOSS for the VAT due to cross-border transfers of own goods by which the output VAT due on cross-border transfers could be reclaimed. We acknowledge that the proposal of a full extension of UOSS on a VAT recovery feature would not gain the full support of Member States. However, we have formulated two possible policies that would be optimal to tackle the above concern.

    Firstly, we believe that there should be applicable VAT exemption with credit to the transfer of own goods in the country of arrival, thus forming an equivalent VAT cash-flow position today. This solution has multiple benefits. Since no VAT reporting requirement and refund are required from the EU Member State of arrival, companies transferring of own goods would not face the cash-flow cost. Given that there is no net VAT revenue associated with movements of own goods in almost all cases, there is an evident similarity with the state of play as it is today. This applies to the outputs and inputs netting off in the same VAT return. On a technical note, it is worth mentioning that extending UOSS functionality would require a simple adaptation of the system. It could be implemented into the broader DRR initiative. Hence, we perceive this solution as the easiest to implement for both taxpayers and national tax authorities level.

    Alternatively, we opt for limiting the VAT cash-flow disadvantage by strengthening the VAT recovery mechanisms for non-established entities. In our view, creating more straightforward claim procedures under the Council Directive 2008/9/EC (know as ‘8th Directive’) for taxable persons registered in the UOSS – both EU and non-EU established. On a practical note, this would enable cash-flow cost without separate VAT registration for EU companies and entail output VAT reporting requirement, which would remain on the transfer of own goods. VAT refund requests would have to submit from the EU Member State of arrival due to the lack of VAT recovery feature built into the UOSS. This would require implementing specific changes to cross-border refund schemes currently in operation. The first change would need to extend the cross-border refund eligibility to VAT incurred on intra-EU transfer of own goods which VAT has been paid through the UOSS. It would apply to both EU and non-EU enterprises.

    Additionally, a period specified in the 8th Directive for processing reclaims would need to be significantly reduced. It would mainly relate to VAT self-accounted on cross-border transfer of own goods. We suggest linking the UOSS with data in the 8th Directive claim system. Validation of VAT claimed on cross-border transfers on own goods shall be processed promptly matching claim and payment done through the UOSS. This will enable relevant Member States to refund the VAT immediately.

    To sum up, ZPP recommends a single EU VAT registration model that includes B2C and B2B supplies and the transfer of own goods. Both options will reduce cash drag and total VAT cost on transfers of own goods. The ultimate goal of the legislator shall be to increase VAT compliance across the block while levering incentives for the companies by improving investments put into developing UOSS for both governments and taxpayers.

    Proposals to improve the functioning of IOSS

    We believe it should be of the legislator’s highest concern to improve the security of the IOSS system. That is why we identified in our expertise specific proposals to make the IOSS more fraud-proof and improve its performance.

    Firstly, we suggest making the IOSS obligatory for all business entities, which would be a complementary solution. In any proposal, we find covering all deemed suppliers, such as marketplaces, essential in the short term. The reason is to ensure a level playing field by countering unfair market practices (i.e. undervaluing goods or migration to the marketplace, which have not opted into IOSS, thus misuse of system’s numbers.

    Secondly, we state that the European Commission shall monitor the system in order to protect it from the misuse of IOSS numbers. This can be done by comparing deviances reported by the Member States on the number of parcels declared through customs under the corresponding IOSS number and on IOSS returns. This would apply to numbers whose deviances cannot be explained by other factors than misuse, ex. accounting error.

    Thirdly, currently biding regulations create many possibilities for its legal interpretation and, consequently, strive the complexity for the customs clearance at the border. This might lead to certain inconsistencies, beginning with the supplier opting out to use the IOSS or parcels, including items excising duty regulations. Moreover, when the parcel is sold to a business or private customer. Avoidance of these frictions shall lead to higher satisfaction for customers and suppliers and reduce the workload for customs authorities, whose capacity shall be focused more on countering fraud.

    We notice that high-value shipments (over 150 EUR) are subject to customs duties. Thus there are to be included in the taxable base for VAT purposes. That is why we suggest prioritising expanding the IOSS to higher value shipments. Companies might not necessarily know the customs duty due on products at the point of sale. For this reason, we recommend adjusting legal requirements over interaction with customs duties carefully.

    On the other hand, there is common dependence on increasing the EU customs duty alongside increasing the IOSS threshold. For that reason, we believe it should be considered to raise the customs duty threshold. The European internal market has a lower threshold than other major markets globally. Less costly VAT collection would compensate higher trade-off; hence increased IOSS threshold would balance the lost duty. Duty rates in the EU are relatively low compared to VAT rates, so based on our expertise, we believe that the increased duty exemption would be overall beneficial to the system’s functioning.

     

    See more: 09.05.2022 ZPP’s contribution to the Commission’s consultation on the VAT in a digital age

    Position of the Union of Entrepreneurs and Employers on the Consumer Credit Directive review

    Posted on by Weronika Marzec

    Warsaw, 26 April 2022 

     

    Position of the Union of Entrepreneurs and Employers on the Consumer Credit Directive review

     

    The European Commission has proposed a new Directive regulating consumer credit in June 2021.[1] The proposal is intended to replace the existing Consumer Credit Directive of 2008.[2] The draft rationale states that the current legal Act has not fully met its objectives, and therefore a revision is necessary. The aim is to introduce provisions that provide a clear legal framework for the financial industry’s economic activities and adapt regulations fit for the digital transformation. The rapidly expanding possibilities of electronic payments and socio-economic trends following it are causing consumers to change their habits in favour of the use of tools that have not yet been legally regulated.

    The change in consumers’ behaviour necessitates an appropriate technological adaptation of financial products. This is due to the progressive digitalisation of commerce, payment methods and financial services. As a result, creditworthiness assessment mechanisms are often based on automated decision-making systems and products information is commonly provided in electronic form. The legislation aims to harmonise laws at the European level and strengthen consumer protection.

    The Union of Entrepreneurs and Employers (ZPP) recognises the need to revise the provisions of the Consumer Credit Directive. We believe that it should create a legal framework that stimulates the development of the financial technology sector, which is undergoing significant changes and not make excessive barriers to the development and innovation of European businesses. Regulation should seek to strengthen consumer protection and increase consumer welfare in the digital environment through access to modern and secure digital tools. In our analysis of the proposal’s text, we identified several solutions in the draft that may be detrimental to the development of FinTechs in Europe and negatively affect the quality of available digital tools and consumer satisfaction with their use. In the following position paper, we set out our concerns regarding the revision proposal.

    Buy-Now-Pay-Later

    The development of FinTechs in Europe is very dynamic. There are already over 300 such companies in Poland, and the vast majority of them are young enterprises not older than 4 – 5 years.[3] The lack of regulations excessively limiting the use of modern digital tools is of great importance for the development of financial technology companies. Currently, the fastest-growing functionality in e-commerce is the ‘buy-now-pay-later. This enables the consumer to purchase online and pay later with no fee (or a very low fee). This instrument kicked off in Sweden and has become popular in Scandinavian countries. It is now rapidly gaining popularity in Europe as the e-commerce sector develops. The data presented shows BNPL’s share of the total e-commerce payment industry at 7.4 per cent of the European market, over 20 per cent share in the Swedish market and only four per cent lower share in the German market. This positions BNPL as an ordinary payment instrument for European consumers.

    Access to secure financial services is beneficial to consumers and allows them to fulfil their daily needs. Low-interest (or interest-free) online loans are, as a rule, low-rate financial instruments. Therefore, they are not equivalent to high-value bank loans to purchase a house or a car. BNPL has a low risk of increasing consumer insolvency. BNPL operators offer many solutions to fit the product to the customer’s needs. However, the ability to create tailored offerings for customers may be limited due to disproportionate regulatory burdens on operators, which may lead to the creation of instruments that are unintuitive and incomprehensible to consumers.

    Creditworthiness assessment

    The creditworthiness requirements introduced by the proposed Directive should be customised to the type of financial commitment. The different lengths and costs of credit should determine the adequate assessment of credit risk in relation to the actual threat of insolvency. Socio-economic factors should influence the distinction between BNPL as a flexible payment option, loans with a high-interest rate or additional charges and products with a high commitment amount. Furthermore, e-commerce companies have their own reliable debt risk assessment systems based on online purchase history or credit fraud databases. This makes BNPL a low-risk service which should be reflected in the proposed Directive. In addition, it is a service characterised by immediate execution, so the traditional method of credit assessment based on manual verification of documents, such as income certificates, is inadequate for the needs of e-commerce and more costly than an assessment based on automated systems. Consumers may be reluctant to share their documents online, or it may prove too burdensome. As a result, this would be at the loss of FinTech companies and exclude some consumers from accessing credit tools.

    Low-value loans

    The current Act includes under the scope loans between €200 and €75,000. The proposed Directive extends its provisions to all loans with a value equal to or less than €100,000. This means that the Directive provisions will cover small purchases using BNPL.

    Many BNPL users do not perceive this financing method as a loan. This is due to the tool’s flexibility, which can be tailored to the needs of a specific offer. It can take the form of a delayed repayment for a set period (e.g. 30 or 60 days), or it can be spread in instalment. Another possibility is to buy ‘on trial’ without making an immediate payment. Free trial shopping is complementary to the online shops’ free returns policies. The above makes it difficult for the consumer to associate BNPL with classic consumer credit. It is also not entirely clear how the different types of BNPL should be classified. Depending on the service provided, it can take the form of various contact obligations known to law.

    Pre-contractual information obligations

    Another factor that may negatively affect the development of innovative financial products may be the excessive pre-contractual information obligation enshrined in the draft Directive. FinTech products are becoming increasingly popular thanks to simple and transparent rules. This is a major difference from traditional banking products, burdened with restrictive information obligations. Loan amounts in BNPL are low and short-term, so there is no need to provide detailed information on held commitments.

    Moreover, a large number of users purchase through mobile devices. Consequently, BNPL is also most commonly used for purchases via mobile phones or tablets. The introduction of a broad information obligation will result in the illegibility of the proposed offer. It may result in the unclarity of the service to the consumer’s detriment. In addition, it might lead consumers to give consent without knowing the actual terms of the agreement. This can lead to a dangerous situation called ‘consent-fatigue’. This is a phenomenon where the user is presented with a large amount of information to read and accept before using a product or service. A large amount of information shown causes a feeling of overwhelm on the consumer, who wants to use the tool as efficiently as possible without time-consuming familiarisation with voluminous information content. This psychological effect leads to a threat to the consumer’s attention who, accepting the rules without familiarisation, may fall prey to fraud and accept unfavourable conditions. This is a negative phenomenon resulting from a disproportionate information obligation on the operator. Considering the above, we believe that the increased information obligation will not benefit the consumers if an effective way of presenting and prioritising the information is not ensured.

    In conclusion, we recognise the need to review consumer credit legislation and adapt it to the new demands of digital transformation. However, we note that specific provisions of the new Directive may halt the dynamic development of FinTech companies in Europe and be detrimental to consumers. Given the importance of consumer protection in the line with the case-law of the Court of Justice of the EU and the legislative activity of the European Institutions, there is no doubt that the welfare of consumers is a value that should be paramount when creating a new law. For this reason, we urge European legislators to consider the comments made above in order to make the provisions of the Consumer Credit Directive the most beneficial to the European economy.

    ***

    [1] https://ec.europa.eu/info/sites/default/files/new_proposal_ccd_en_3.pdf

    [2] https://eur-lex.europa.eu/legal-content/PL/ALL/?uri=CELEX%3A32008L0048

    [3] https://www.ican.pl/b/jak-wyglada-polski-fintech-rzut-oka-na-branze/PMQpOzRdk

     

    See more: 26.04.2022 Position on the review of the Consumer Credit Directive

    The companies that decided to continue their operation in Russia have nothing to do with “the social responsibility of the business” And what does their fair CIT settlement in Poland look like?

    Posted on by Weronika Marzec

    Warsaw, 8 April 2020

     

    The companies that decided to continue their operation in Russia have nothing to do with “the social responsibility of the business” And what does their fair CIT settlement in Poland look like?

    REPORT OF THE UNION OF ENTREPRENEURS AND EMPLOYERS

     

    The disgusting and unjustified Russian invasion of Ukraine has led to widespread ostracism and consumer boycotts. The broad scope of the sanctions meant that some companies had limited choice as far staying in Russia goes. Companies in the banking, energy or high-tech sectors have had to submit to decisions ordering to halt the trade immediately. The only companies that had a say in all of this were the ones of the retail and manufacturing sectors. Most of them have made this decision on their own – and in the eyes of the ZPP the only right decision there is – to leave this country. But not all of them.

    ZPP has made a decision to look into the companies that have chosen to stay in Russia. Continuing our series of publications on how some multinational corporations go about their tax settlement, we have turned our attention to entities that have decided to continue doing business in the Russian Federation. In the course of the analysis it turned out that a significant number of these entities pay marginal income tax in Poland – in many cases, in relation to their revenues and the scale of their activity, multiple times lower than in Russia.

    – Companies like to boast about their social responsibility, but the real value of these declarations is verified in moments of trial, when basic decency has to be demonstrated – says Jakub Bińkowski, member of the board and director of the Law and Legislation Department at ZPP.

    – Maintaining the decision to continue operating in Russia feeds the aggressor’s budget and generates funds for the war-related activities. This is difficult to understand, all the more so since doing business in the country now involves gigantic risks and the purchasing power of Russian consumers is consistently decreasing. We are not particularly surprised that those who have decided to continue operating in this country, despite everything that’s happening, pay almost symbolic CIT in Poland. However, this is an additional reason why urgent reform of the tax system is necessary. Especially since the same entities pay much higher sums to the Russian budget – adds Jakub Bińkowski.

    However, the information presented in the report is also a reminder of the extent to which companies remaining on the Russian market contribute to the country’s budget, also by paying corporate income tax. They are thus becoming sponsors of Vladimir Putin’s regime and, indirectly, of the ongoing war-related activities.

    Leaving aside the current context, this phenomenon once again shows how inefficient the Polish tax system is, particularly in the area of tax paid by capital companies. We have repeatedly argued that CIT is de facto voluntary, as it is paid only by those entities that do not engage in tax optimisation.

    Companies cited in the report include Makro Cash&Carry, Auchan, Astrazeneca Pharma, Decathlon, Leroy Merlin, but also Rockwool, Bonduelle, Total Polska (Totalenergies Group), Glaxosmithkline Pharmaceuticals and Schneider Electric. It turns out that these companies have not only decided to stay in Russia, but also systematically pay CIT at a fraction of a percent of revenue.

    – We went a step further in our analysis and checked what the tax practice of the same companies looks like on the territory of the Russian Federation – says Kamila Sotomska, deputy director of the Law and Legislation Department of the ZPP.

    – Logically, the same entities that do not pay CIT in Poland would not pay it in Russia in order to maximise global profit. Well, apparently not. Let’s take Leroy Merlin – in 2020 alone it paid almost three times as much tax in Russia as it did for nine years in Poland. Auchan paid five times more to the Russian budget in 2020 than to the Polish tax in 2012-2021 – she stresses.

    More details in our report: How much CIT do companies that stayed in Russia pay in Poland?

    Opinion of the Chief Energy Technology Specialist at The ZPP: achieving energy autonomy requires additional legislative action

    Posted on by Weronika Marzec

    Warsaw, 6 April 2022

     

    Opinion of the Chief Energy Technology Specialist at The ZPP: achieving energy autonomy requires additional legislative action

     

    On Thursday, 31 March, a signing ceremony took place for an appeal to unlock investment opportunities in onshore wind energy. Known as ’10H law’, it can be considered a key piece of legislation for the Polish energy sector in the context of the country’s current geopolitical situation. As a result of the war in Ukraine, energy independence is becoming a priority both politically and economically. This is an aspect that requires us to act in an extremely quick and focused manner.

    The only sources that can rapidly replenish our energy balance in the near future – significantly increasing the supply of energy – are onshore wind farms and large-scale solar sources. ZPP has been calling for a special legislative priority to streamline these investments for a long time, presenting the benefits for the entire Polish economy of such projects.

    In the face of a rapidly increasing green energy deficit, both of these sources are crucial, especially for companies exporting to European markets. Investments in the developing distributed energy also have an impact on the security level in the country. The war in Ukraine has shown how easy it is to take over large power stations and the consequences this can have on a security level in the country. In contrast, it is more difficult to disrupt a million of small, distributed solar and wind installations.

    We believe that every action towards increasing security and achieving energy independence in Poland should be strongly supported, hence our decision to join the appeal for a quick unblocking of investment in onshore wind energy. This is particularly important if we want to save a certain proportion of our coal-fired power generation from political death, and thus obtain the Union’s approval to extend the process of moving away from coal. Only consistent action in this area can ensure our energy autonomy.

    The development of distributed energy will be important for the entire Polish economy, provided that it is an integral part of the whole programme of energy transformation in the country. The recently presented assumptions for the revision of the Energy Policy of Poland assume dynamic development of this form of energy, so we hope that the rapid restoration of investment opportunities for onshore wind energy will be one of the most important objectives of the Polish government.

    We would like to once again draw attention to the enormous potential offered by the development of large-scale solar sources on post-industrial areas. A large part of these places is in the hands of state-owned companies with investment and connection capacities. The only problem in this case is the exceedingly long time it takes to obtain building permit.

    Legislative shortening of the deadlines for issuing these permits on post-industrial and post-mining sites would give us an additional 4 to 5 GW of green power in just 3 to 4 years. Amending the Wind Power Investment Act that would liberalise the 10H rule provide another 5 – 7 GW of capacity, thus making the achievement of 20 – 25 GW of installed green powers in 2027 fully feasible. This, in turn, translates into 40 to 45 terawatt hours of energy per year, which would come from distributed onshore installations.

    Based on the above calculations, it can be assumed that in 2027 we would be able to produce 25-30% of our energy solely from land-based, distributed and renewable sources, and this would already constitute a clear step towards Poland’s energy sovereignty. We turn to the decision-makers and urge them to act quickly in proceeding and passing the necessary legislation that will enable us to achieve autonomy in the area of energy supply.

     

    Włodzimierz Ehrenhalt
    Chief Energy Technology Specialist at the ZPP

     

    See: 06.04.2022 Opinion of the Chief Energy Technology Specialist at The ZPP: achieving energy autonomy requires additional legislative action

    The stance of the ZPP on the Act of 7 April 2022, on special arrangements to prevent the promotion of aggression against Ukraine and to protect national security

    Posted on by Weronika Marzec

    Warsaw 12 April 2022 

     

    The stance of the ZPP on the Act of 7 April 2022, on special arrangements to prevent the promotion of aggression against Ukraine and to protect national security

     

    On 30 March 2022, the draft law on special arrangements to prevent the promotion of aggression against Ukraine and to protect national security was submitted to the Polish Sejm. The law aims to restrict the activities of persons and entities linked to Russia, which on 24 February 2022 attacked Ukraine, as well as Belarus, which supports the Russian Federation in these actions. The bill was very quickly adopted by the Sejm by a large majority – 445 in favour, 0 against and 11 abstentions. The bill has been forwarded to the Senate and will most likely be passed and signed by the President in the coming days.

    This project focuses on the possibility of ‘freezing’ the assets of individuals and entities linked to Russia and Belarus that support aggression against Ukraine. Entities from these countries will also not be able to participate in tenders organised under the public procurement procedure. In addition, individual persons may be included in the list of foreigners whose residence in the territory of the Republic of Poland is undesirable. These are, therefore, relatively comprehensive measures to eliminate both the physical and economic presence and capital of specific companies and individuals.

    The aforementioned sanctions may be imposed on entities and persons who will be included in the list maintained by the appropriate Minister in charge of internal affairs, responsible for making administrative decisions in this regard, based largely on the provisions of the Code of Administrative Proceedings. The proceedings in the matter of an entry may be undertaken by the Minister ex officio or at the request of one of the entities enumerated in the Act (e.g. the heads of the Central Anticorruption Bureau, the Internal Security Agency, the Foreign Intelligence Agency, the Military Intelligence Service, the Military Counterintelligence Service and the National Public Prosecutor). The list will be published in the Bulletin of Public Information on the Ministry’s website. It is therefore important that businesses keep their contractors, both current and future, under review for potential sanctions stipulated in the provisions of the Act.

    Pursuant to the Art. 3 sec. 2 persons and entities who directly or indirectly support the Russian aggression against Ukraine or severely violate human rights, repress civil society and democratic opposition, or whose activities pose another serious threat to democracy or the rule of law in the Russian Federation and Belarus may be included in the list. Entities may also be included on the list if they are directly related to previously listed entities, in particular through personal, organisational, economic or financial links.

    It is also worth noting that the Minister in charge of internal affairs will be able to limit the scope of justification of the decision on entry and removal from the list for reasons of state security or public order in accordance with Art. 3 sec. 9 of the Act.  This provision is meant to ensure state security, e.g. in the dissemination of classified information.

    Another important step provided for in the Act is to prohibit the import and transit of coal from Russia and Belarus through the territory of Poland. The entities trading in coal will have to document its origin and keep the relevant documents for 5 years.

    The Act will also prohibit the use, application or promotion of symbols or names supporting the aggression of the Russian Federation against Ukraine (Art. 16 of the Act). The ban will apply, for example, to the ‘Z’ symbol used to mark the military vehicles of the aggressor’s army and, in recent weeks, also used by supporters of the policies of Russian President – Vladimir Putin. Violation of the ban is punishable by imprisonment of up to 2 years.

    It is important to note that entities that fail to comply with their obligations under the Act with respect to, for example, freezing funds, funds or resources of persons identified on a list maintained by the Minister, violate the prohibition on the import and transit of coal, take action to circumvent the prohibitions or otherwise violate the prohibitions set out in the Act may be subject to financial liability. The fine for individual violations can be up to PLN 20 million.

    In view of the current geopolitical situation, the introduction of the Act on special measures to prevent support for aggression against Ukraine and to protect national security is undoubtedly justified. Russia is not a reliable economic partner for Poland, and the measures provided for in the Act may restrict funding for arming activities of a state which does not respect the sovereignty of its neighbours and which, in the future, could potentially deploy its troops even against our country. It is worth noting that the value of Polish exports to Russia is around 36.6 billion PLN, while the value of imported goods is 77.8 billion PLN. This means that Russia is not, on an economy-wide basis, a key trading partner, although certainly in many industries the proposed measures could be very noticeable. It is therefore crucial to urgently secure other channels of trade. In view of the above arguments, it must be assumed that it is certainly more important to guarantee the security of the state and to cut off trade with Russia than to go through some temporary trade problems.

    It should be pointed out, however, that the Act does not provide details on how traders should fulfil their obligations under the agreement in question, how they should behave towards listed entities under ongoing contracts. It is important for Polish companies to have information on the procedure for freezing funds, securing assets and potential liability for loss of value, damage or destruction.  Guidance in this regard seems necessary to avoid the potential risks involved in even unintentional breaches of the Act.

     

    See: 12.04.2022 The stance of the ZPP on the Act of 7 April 2022, on special arrangements to prevent the promotion of aggression against Ukraine and to protect national security

    Commentary of the Union of Entrepreneurs and Employers (ZPP) on the progress of work on the Digital Services Act

    Posted on by Weronika Marzec

    Warsaw, 15 April 2022

     

    Commentary of the Union of Entrepreneurs and Employers (ZPP) on the progress of work
    on the Digital Services Act

     

    Digital Services Act (DSA) will soon amend the E-Commerce Directive that has been in place for more than 20 years. Work on the new regulation has been ongoing continuously since late 2020. The trilogue – a trilateral negotiation between key EU institutions – is expected to conclude early this month. However, we are now seeing the emergence of numerous proposals that were not included in the negotiators’ original mandate.

    The disproportionality of the crisis response mechanism

    Among the most recent proposals is the Crisis Response Mechanism (CRM), which was created to enable institutions to counter Russian disinformation attacks efficiently. We welcome that the EU institutions take decisive steps to fight against Russian propaganda. Nevertheless, we have some doubts as to whether introducing the proposed provisions in DSA at this stage of the negotiations is the best way to tackle this problem.

    At the request of the French Presidency, the Commission has proposed introducing provisions that could force large technology companies to quickly adapt their platforms and increase the number of staff moderating content during major crises such as natural disasters, terrorist attacks or war. The new DSA Article 25(a) would empower the Commission to require specific actions only based on a recommendation from a Council of European National Regulators. Paris has suggested that a two-thirds majority of regulators would be needed. Technology companies’ efforts to tackle disinformation or problems related to a specific crisis would be legally limited to three months. At the same time, the Commission would have to keep its decisions transparent.

    This proposal has been protested against by 24 citizens’ organisations, who point out in their open letter that the European Commission should not be empowered to declare an EU-wide state of emergency unilaterally. Furthermore, these organisations note that the CRM is far from respecting international human rights standards of legality, legitimacy, necessity and proportionality, and they call for reformulation.

    Moreover, the new Article 25a of DSA is intended to empower national digital coordinators to require smaller platforms to comply with risk mitigation obligations that usually fall on very large platforms only. Such a provision appears to place a disproportionate burden on smaller platforms, whose ability to comply with the requirements mentioned above will be limited in practice, especially in the short term.

    Ultimately, attempts to combat Russian disinformation may be undermined by other provisions found in DSA. Article 15(2) requires platforms to provide information on the facts and circumstances as well as the means used whenever content-related activities are undertaken. This will provide disinformation actors with full knowledge of how platforms combat disinformation and reduce the visibility of harmful content. As a result, in an effort to increase transparency, DSA will make it easier for bad actors to fool security systems and, consequently, more complex to fight disinformation. In the current situation, the EU institutions should create instruments that allow platforms to fight against disinformation actions carried out by third countries on a massive scale, rather than introducing new solutions to a horizontal regulation such as DSA at such a late stage.

    Return of the ban on targeted advertising

    In a plenary vote in the European Parliament, MEPs rejected a complete ban on targeted advertising. As a result, they voted to restrict the targeting of minors and targeting using sensitive data. We welcomed the EP decision. We believe it strikes the right balance between user protection and business rights. A total ban would have hit SMEs, depriving them of a cost-efficient way to reach their customers and severely limiting their growth opportunities. Therefore, we watch with concern the amendments tabled by MEPs aimed at achieving a de facto ban on targeted advertising.

    Before discussing the EP’s latest proposals, it is first necessary to draw attention to the so-called ‘known minor problem’. Platforms would have to verify minors’ age to be able to restrict the use of targeted advertising. In the absence of general age verification on the Internet, platforms have to process user traffic data to determine age based on activity. Paradoxically, a ban on targeting could, in theory, lead to more tracking of children’s online activities.

    To address this issue, the EP proposed an amendment to Article 24(1)(b), which states that ‘compliance with the obligation set out in the first subparagraph shall not entail the processing by online platforms of additional personal data on minors in order to verify the age of the recipient of the service’. Whilst we recognise the need to promote child safety through data minimisation, we believe that a provision worded in this way will be difficult to implement in practice and will reduce targeted advertising across all age groups. We propose that the provision be amended to prohibit excessive, rather than an additional, collection of personal data for age verification purposes.

    Moreover, MEPs propose to extend the ban if the platform has doubts about whether the recipient is a minor (Article 24(1)(c)). This also means expanding the prohibition to the user when age verification is not possible. Given the current state of technology, such a provision could lead to a de facto ban on personalised advertising. This provision should be limited to cases where the platform has serious grounds, not just doubts, to believe that the recipient is a minor to avoid negotiators walking out their mandate. A provision worded in this way will simultaneously protect minors.

    Extension of know-your-business-customer

    As a final point, attention should be drawn to the proposal to extend the know-your-business-customer rule, which obliges Internet Service Providers (ISPs) to collect information that identifies business users in order to verify their identity. KYBC aims to improve online security by halting certain entities from using legitimate services to conduct illegal business anonymously. Assuming that the list of information required to be obtained from ISPs is proportionate and not an unreasonable administrative burden, the proposal should be viewed positively. However, during the January negotiation rounds, it was proposed to extend this principle to all types of ISPs, thus covering market places and social media, instant messaging, or streaming services.

    In order to understand the implications of the KYBC extension, it is important to remember that DSA, like the E-Commerce Directive, is based on a prohibition of general internet monitoring. Such an injunction has been rejected from both the E-Commerce Directive and DSA, as it undermines fundamental values such as freedom of expression and could lead to censorship (i.e. excessive blocking or removal) of lawful content. Extending the KYBC to all intermediate service providers means extending it to all content that appears on the Internet. Therefore, it is hard to imagine in practice how the application of such a rule would take place without general monitoring of the Internet while still meeting DSA’s stringent requirements for human factors provision.

    The Union of Entrepreneurs and Employers actively participated in the work on the Act and, from the very beginning, called for solutions that would not overburden digital businesses. At the end of DSA negotiations, we maintain this call and urge policymakers not to place impossible demands on digitally active companies.

     

    See more: 15.04.2022 Commentary of the Union of Entrepreneurs and Employers (ZPP) on the progress of work on the Digital Services Act

    Memorandum of the Union of Entrepreneurs and Employers (ZPP) on the economic situation in Ukraine and its consequences for Polish companies

    Posted on by Weronika Marzec

    Warsaw, 31 March 2022

    Memorandum of the Union of Entrepreneurs and Employers (ZPP) on the economic situation in Ukraine and its consequences for Polish companies

     

    On 24 February 2022, the Russian Federation invaded Ukraine. Hostilities spread over almost the entire territory of our eastern neighbour. The extent of the damage after nearly a month of attacks is counted in the tens of billions of dollars. Almost all critical infrastructure was either destroyed or severely damaged.

    The humanitarian disaster in Ukraine brings with it a migrant and economic crisis for the entire region, the economic impact of which will be felt around the world for years to come. Ukraine is one of the largest producers of cereals and vegetable oils. The production crisis will lead to a spike in prices for the food industry on world markets. This has a major impact on Poland’s economy due to the disruption of supply chains and the almost total lack of business opportunities in war zones. Hundreds of Polish companies in Ukraine have been forced to temporarily close or relocate their businesses and offices.

    At present, a comprehensive assessment of the foreseeable impact of the situation on Polish business is probably impossible. Polish investors are left to actively monitor changing regulations, assess the safety of conducting business activities and hope that the war ends as soon as possible. 

    1. General information about the Ukrainian economy (state before the Russian invasion). Expected reforms and changes to business regulations.

    In the first years after gaining independence in 1991, Ukraine was a heterogeneous country plagued by internal conflicts and corruption. The country’s economy regularly faced economic crises, internal power struggles which were not conducive to development and foreign investors’ confidence. It was not until 2014 that the country shifted and chose a Western course for further development which ended in partial Russian aggression. Recent years, however, have seen slow reforms of the judiciary system, a fight against corruption (increasingly successful and producing tangible results), opening more to Western investments and, finally, land reform. The country’s development decisively accelerated after 2018 and even the COVID-19 pandemic did not manage to diminish Ukraine’s very good prospects in the short and medium term. 


    *Data does not include GDP of occupied Donbass and Crimea, **Source UKRSTAT


    *Data does not include GDP of occupied Donbass and Crimea, **Source UKRSTAT

    Based on the above data, we can conclude that the Ukrainian economy has been growing slowly but steadily, despite the large expenditure on armaments since the beginning of the war with the Russian Federation in 2014. Another interesting issue is the level and origin of foreign direct investments over the last 10 years. Even before 2015, Russian capital from Cyprus, where it was mostly legalised, was at the top of the list of largest investors. Following the annexation of Crimea, the structure of foreign capital in Ukraine changed significantly. It should be mentioned that in recent years Poland has not only become one of Ukraine’s main economic partners, but the level of Polish investment in the country itself is one of the highest in history and it has been showing an upward trend. It should be noted, of course, that the rate of investment has slowed sharply in 2020 – 2021 due to the restrictions on economic activity caused by the coronavirus outbreak.


    *Source UKRSTAT


    *Source UKRSTAT

    An example of the changes is the “Dia City” bill, which introduced far-reaching changes and tax reliefs for almost the entire IT sector (the bill came into force on 1 January 2022). “Dia City” aimed to develop the entire IT sector, fight against the grey employment market and introduce low and transparent taxes for foreign investors as well as their employees. The main objectives of the bill are as follows:

    a) A company that has passed the verification may choose the method of corporate taxation: 9% of dividend tax, or 18% income tax under the general rules.

    b) When profits are distributed by a participant in the Dia City programme to a non-resident founder, the tax benefits provided for in international conventions for the elimination of double taxation shall apply regardless of the corporate tax payment system chosen.

    c) Preferential taxation of employees:

    based on an employment agreement, personal income tax (hereinafter referred to as “PIT”)
    – 5% single social security contribution,

    – 22% minimum wage for PIT,
    – 1.5% military tax,

    if an employee’s total remuneration is higher than EUR 240,000 per year, all income above this limit shall be subject to 18% personal income tax.

    d) Dividends paid by IT companies to their founders – natural persons (both residents of Ukraine and non-residents) shall be exempt from taxation in Ukraine provided that the dividends are paid no more often than once every 2 years.

    1. The banking system of Ukraine during the war

     The operation of the banking system and the foreign exchange market in Ukraine during wartime is regulated by a resolution of the National Bank of Ukraine of 24 February 2022:

    – all banks operating on the territory of Ukraine shall continue to provide their services and operate in their field branches as part of their business,

    – banks shall continue to provide both natural persons and companies with access to safe deposit boxes,

    – domestic transfers in Ukrainian currency shall be unlimited,

    – cash deliveries to ATMs shall takes place without restrictions,

    – The NBU shall refinance banks without restrictions to maintain liquidity for up to one year with the possibility of extension for another year.

    The relevant resolution also provides for the introduction of temporary restrictions from 24 February 2022, namely:

    – suspension of foreign exchange market operations as of 24 February 2022, with the exception of the sale of foreign currency to the bank’s customers,

    – UAH exchange rate freeze as of 24 February 2022,

    – Limiting cash withdrawals from a customer’s account to UAH 100,000 per day (except for salaries and social benefits), except for enterprises and institutions ensuring the implementation of mobilisation plans (tasks), the Government and individual authorisations of the National Bank of Ukraine,

    – prohibiting the transfer of funds from customer accounts in foreign currencies, except for enterprises and institutions ensuring the implementation of mobilisation plans (tasks), the Government and individual authorisations of the National Bank of Ukraine; on 4 March 2022, Resolution No.: N36 of the National Bank of Ukraine lifts the prohibition on the transfer of funds (except for Russian and Belarusian roubles) to residents’ accounts in banks for export transactions.

    – introducing a moratorium on cross-border payments in foreign currencies (with the exception of enterprises and institutions ensuring the implementation of mobilisation plans (tasks) and individual authorisations of the National Bank of Ukraine),

    – suspension of spending operations conducted through the banks’ operation on the accounts of residents of the country that invaded Ukraine.

    On 8 March, the NBU eased restrictions on the foreign exchange market by introducing Resolution no. 44 of the NBU Board of Directors of 8 March 2022. Martial law requires the NBU to gradually ease and clarify the list of restrictions on the foreign exchange market. For this purpose, from 8 March 2022, the National Bank of Ukraine:

    – provided banks with the possibility to open accounts for soldiers and to carry out their identification and verification on the basis of a call-up paper,

    – enabled customers in areas at risk of occupation by an aggressor state to withdraw cash
    in domestic and foreign currency without quantity restrictions, and to purchase cash in foreign currency and precious metals with physical delivery, subject to the availability of cash or precious metals at bank branches. The decision to carry out such an operation shall be made by the General Manager of the bank. The General Manager may also delegate this right to a Branch Manager of the bank,

    – established that the prohibition of transactions in Ukraine using the accounts of residents of Russia or Belarus and legal entities whose ultimate beneficial owners are residents of Russia or Belarus does not apply to social benefits, salaries, utilities, taxes, fees and other mandatory payments,

    – extended the possibility for residents and non-residents to make transfers to charitable foundation accounts not only in hryvnia but also in foreign currency. This applies to charitable foundations whose purpose and areas of charitable activity are the promotion of defence capabilities and state mobilisation readiness, support of the Armed Forces, territorial defence of Ukraine, social protection, health care and other pressing martial law issues,

    – clarified that settlements of documentary and standby letters of credit / guarantees / counter-guarantees granted (confirmed) from 24 February 2022 are prohibited. The NBU made an exception only for the cases of payments for critical imports, settlements with MFIs and other operations of bank customers, the list of which is set out in points 2-6, paragraph 14 of Resolution no. 18 of the NBU Board of Directors of 24 February 2022.

    The NBU also decided that the bank may exchange funds in Russian or Belarusian roubles coming from abroad for the purposes of export and import of goods into another currency on the international foreign exchange market and continue to book them on customers’ accounts.

    1. Settlements with the Ukrainian tax authorities during the war

    In Ukraine, a moratorium on penalties related to non-compliance with tax obligations has been introduced for both natural and legal persons, as confirmed by the authorities responsible for assessing emergency situations:

    “Ukrainian Chamber of Commerce and Industry confirms that the circumstances of martial law from 24 February 2022 until the official end of the war are extraordinary, unavoidable and objective circumstances for business entities and/or natural persons under an agreement, separate tax and/or other obligations, which were performed in accordance with the terms of the agreement, statutory or other regulations, the performance of which became impossible within the prescribed period due to the occurrence of such force majeure (force majeure).”  The occurrence of force majeure is confirmed by the Ukrainian Chamber of Commerce and Industry on the basis of Art. 14, 14-1 of the Law “On Ukrainian Chambers of Commerce and Industry” of 2 December 1997 № 671/97-VR, Statute of the Ukrainian Chamber of Commerce and Industry.

    The law exempts taxpayers from financial liability for tax offences and violations of other regulations resulting from force majeure (paragraph 112.8.9 of the Tax Code of Ukraine; CC), provided that the Ukrainian Chamber of Commerce and Industry confirms the occurrence of force majeure. In the case of force majeure, the tax authorities shall not apply penalties if the taxpayer is not able to perform the following actions on time:

    1. pay taxes and charges,
    2. file tax returns,
    3. register tax invoices and calculations of adjustments made to them in the Unified Register of Tax Invoices,
    4. register excise invoices and calculations of adjustments made to them in the Unified Register of Excise Invoices,
    5. submit electronic documents containing data on actual fuel residues and volumes of fuel/ethanol traded, etc., but as soon as the state declares the force majeure to have ceased, the taxpayer must fulfil his/her tax obligations.

    At the same time, the Government of Ukraine issued an appeal to all companies operating on the territory of Ukraine to make every effort to conduct (as much as possible) normal operations
    in order to minimise losses to the Ukrainian economy and supply.

    In addition, the Verkhovna Rada of Ukraine passed a law on 17 March 2022 providing for a simplified taxation system for big business, abolishing excise duty on fuel and VAT, exempting private individuals from paying the single social security contribution and more. This was announced by Prime Minister Denys Shmyhal – Law No. 7137-d on the website of the Verkhovna Rada. The document provides for a large number of changes affecting various sectors, as well as small and medium-sized enterprises. This preferential tax regime shall last until the end of martial law.

    Fuel taxes: From now on, excise duties on petrol, heavy distillates and liquefied petroleum gas are EUR 0 per 1000 litres. The rate of value added tax on fuel imports has been reduced from 20% to 7%.

    Big business will be able to take advantage of the simplified tax system and pay one tax. The annual revenue limit was raised from UAH 10 million to UAH 10 billion and restrictions on the number of employees were lifted. The tax shall be 2% of turnover regardless of the type of business activity. The tax relief shall not apply to businesses involved in the sale of excise goods, the gambling industry and the extraction and sale of minerals.

    1. The flow of goods and services between Poland and Ukraine. 

    The Cabinet of Ministers of Ukraine adopted Resolution No. 234 of 9 March 2022 on uninterrupted supply of imported food and feed under martial law. According to the resolution:

     – entities operating in the food market who, as a result of military (combat) activities, are unable to comply with the requirements of Art. 10 of the Law of Ukraine “On the Provision of Food Information to Consumers”, may sell food in the customs territory of Ukraine that is labelled in a language other than Ukrainian. However, larger consignments must contain basic information
    on the origin and ingredients in Ukrainian;

    – foreign humanitarian aid entering the customs territory of Ukraine is completely exempt from the obligation to include a description of the goods in the Ukrainian language.

    Under martial law, the government established new rules for the export of a number of agricultural products.
    In particular, the resolution prohibits the export of:

    – oats,

    – millet,

    – buckwheat groats,

    – sugar,

    – salt,

    – wheat,

    – live cattle,

    – pork and beef meat products.

    In addition, the Cabinet of Ministers of Ukraine is banning fertiliser exports from Ukraine due to martial law in order to maintain balance in the domestic market of important mineral fertilisers. Thus, a zero quota is introduced for their export. This applies to nitrogen, phosphorus, potassium and compound fertilisers:

    – mineral or chemical fertilisers, nitrogen (UKT FEA code 3102),

    – mineral or chemical fertilisers, phosphorus (UKT FEA code 3103),

    – mineral or chemical fertilisers, potassium (UKT FEA code 3104),

    – mineral or chemical fertilisers containing two or three nutrients: nitrogen, phosphorus
    and potassium; other fertilisers; goods of this type in tablets, in packages of a gross weight not exceeding
    10 kg (UKT FEA code 3105).

    This entails a de facto total ban on all exports of the above-mentioned products.

    Exports of the following products were allowed under a specific declaratory licence:

    – wheat and a mixture of wheat and rye,

    – maize,

    – domestic chickens meat,

    – eggs of domestic hens,

    – sunflower oil,

    Obtaining a declaratory export licence means allowing the export of a particular good in a limited quantity. All other goods can be freely exported according to the standard procedure.

    From the point of view of Polish importers, the restrictions in force will not have a significant direct impact on fertiliser prices. However, it is important to remember that the sanctions imposed on Russia and Belarus will already have a significant impact.

    On the other hand, it is obvious that Polish exports to Ukraine are facing a slump; many companies importing Polish goods in eastern and southern Ukraine have been destroyed and some are operating to a limited extent. In the central and western regions of the country, most of the retail chains, distribution, logistics and production companies are operating normally. It should be noted that Poland was Ukraine’s third largest economic partner (after Germany and China).


    *Source UKRSTAT


    *Source UKRSTAT

    1. General situation of Polish business in Ukraine

    As of 1 January 2022, there were approximately 1,000 companies with Polish capital operating in Ukraine, and the scale of Polish investments in the Ukrainian economy was one of the highest compared to other countries. The largest Polish investments concern the following sectors:

    – insurance

    – banking

    – manufacturing

    – construction

    – IT

    – clothing

    – fuel

    – pharmaceuticals

    – furniture.

    For many Polish companies in Ukraine, current events may mean closing their factories, warehouses and offices. A few weeks ago, most foreign companies (not only Polish ones) decided to evacuate key personnel to Lviv in western Ukraine or their home countries. Some companies offered to relocate their employees and their families to other countries and, after martial law was declared, to relocate to areas of western Ukraine.

    Many Polish companies with branches in Ukraine also operate outside the country, which means that foreign projects (for men
    aged 18-60) are on hold. Only the men who meet the following criteria can leave the country:

    – have 3 children,

    – are unfit for military service,

    – are professional drivers with special authorisation to engage in road transport,

    – are the sole guardians of minors,

    Some employees also cannot fulfil their professional duties due to being called up for active military service. For IT companies responsible for key infrastructure, there is an option to withhold conscription for 6 months for key employees. However, they still cannot travel outside Ukraine, even temporarily.

    The Kyiv School of Economics hired Gradus Research to conduct a study, which found that because of the war, as many as 85% of companies in Ukraine work part-time or are closed, including:

    – 1% of companies have closed and have no plans to restart,
     – 35% of companies have suspended operations waiting for better times.


    *Source Gradus Reaserch

    Some Ukrainian companies have decided to change their business activity for the duration of the hostilities, e.g. leading confectionery manufacturer Roshen – humanitarian aid; Carlsberg Ukraine breweries – bottled mineral water.


    *Source Gradus Reaserch


    *Source Gradus Reaserch


    *Source Gradus Reaserch

    To sum up, the situation for Polish business in Ukraine is difficult and deteriorates with every day of hostilities by the Russian Federation. Even at this stage of the war, it will likely take years to rebuild the infrastructure and the economy. Even with substantial financial assistance from Western countries, a return to the past performance by Polish companies is impossible, at least in the short term.

    Ukraine is one of the ten most important foreign markets for Polish business; its proximity and untapped potential since the beginning of the 1990s still provide opportunities for development and stabilisation for many Polish companies. It can already be said that a large proportion of Polish foreign investment in Ukraine has been successful. The companies have strong standing, many customers, and in some cases become local market leaders, employing tens or even hundreds of employees. Unjustified aggression by the Russian Federation can destroy the capital built up over many years. With this in mind, we should consider supporting Polish companies that have built up a reputation for Poland as a reliable business partner over the years.


    See: 25.03.2022 Memorandum of the Union of Entrepreneurs and Employers (ZPP) on the economic situation in Ukraine and its consequences for Polish companies

    Business commentary and recommendations on the economic risks associated with the war in Ukraine

    Posted on by Weronika Marzec

    Warsaw, 17 March 2022 

     

    Business commentary and recommendations on the economic risks associated with the war in Ukraine

     

    The Russian aggression against Ukraine and its consequences have specific economic effects also felt by Polish businesses. Considering that further developments are difficult to predict and that some difficulties are already present, the Union of Entrepreneurs and Employers (ZPP) gathered comments, risk assessments and recommendations related to the current situation from affiliated industry organisations and companies. The material, broken down by sector, is presented below and submitted for the consideration of public administration bodies in the context of potential legislative and organisational measures to be taken.

     

    1. Transport

    Urgent amendment of regulations governing the employment of foreigners

    A significant threat to companies is the shortage of lorry drivers. Until now, Ukrainian drivers have constituted a large and growing group of drivers employed by Polish transport operators. We are already receiving indications from our transport operators that:

    • drivers on leave do not return to work in Poland,
    • drivers who have families in the danger zone want to return to their families,
    • drivers called up for military service also return to Ukraine.

    This may cause both problems with the availability of transport services and further increases in transport prices (operators are already increasing service prices due to soaring fuel prices and extended service times at petrol stations).

    The introduced Act on assistance to Ukrainian citizens has made it possible to employ refugees and legalise their stay. However, problems may arise in international transport. During checks, the driver must often show a passport, which includes a visa and work permit. In the current situation, it should be possible to quickly obtain documents enabling cross-border work so that a driver employed in Poland could easily travel to other EU countries and beyond, for example, to the United Kingdom.

    1. Motor vehicle rental

    There is currently a large group of US citizens involved in helping refugees in our country. The military presence of our American ally in connection with the protection of NATO’s eastern borders is also increasing. In many cases, these people want to rent a car for their activities from a car rental company. Unfortunately, they usually do not have an international driving licence required in Poland for US citizens (the US driving licence is invalid). In such cases, rental companies are legally prohibited from renting cars to persons without a valid licence.

    Given the above, to make it easier for United States citizens to function in Polish, it is desirable that US driving licences should be recognised in our country as a matter of urgency and treated the same as those issued in the European Union.

    1. Pharmacy
    • Enabling pharmacists and pharmacy technicians to access the labour market

    The Act of 12 March 2022 on assistance to citizens of Ukraine in connection with armed conflict on the territory of their country has enabled doctors, dentists and nurses to access the Polish labour market. Given the current labour needs in the pharmaceutical sector, we are requesting that pharmacists and pharmacy technicians be granted a temporary licence to work on the same basis.

    • Allowing mail-order sales of prescription drugs

    Currently, pharmacies are only allowed to carry out mail orders and delivery of medicines, but only over-the-counter medicines and only as far as online pharmacies are concerned. The most critical prescribed (Rx) medicines must be picked up by the patient in a pharmacy. The introduction of delivery of Rx medicines and other reimbursable products (e.g. adult nappies, which are difficult to transport for the elderly) is beneficial from the point of view of patients – in particular, those who need them the most (e.g. elderly and/or disabled individuals). Importantly, pharmacy employees could monitor the correct delivery and temperature, which is important for some products.

    • Amendments to the Pharmaceutical Law regarding advertising of pharmacies and pharmacy outlets

    The Pharmaceutical Law provisions regarding the prohibition on advertising pharmacies make it very difficult to inform patients about the services provided. Pharmacists are faced with different interpretations of the law and different interpretations by the pharmaceutical inspection authorities. These regulations have been in place for ten years without any amendments and are not adequate in the current situation in the pharmacy market and the country as a whole. New services have been introduced in selected pharmacies, including immunisations and diagnostic tests. Moreover, further services, e.g. drug review, are planned to be implemented. For example, because of the advertising ban, pharmacists are afraid to advertise that people can be vaccinated against COVID-19 in their pharmacy, assuming that the pharmaceutical inspectorate will consider this prohibited advertising. Also, in the face of the war in Ukraine and the influx of refugees crossing Poland’s eastern border, placing information in Ukrainian on a pharmacy window or providing help to the needy may be treated as an “encouragement” to visit the indicated pharmacy. As a result, its owner and manager may face the consequences imposed by the pharmaceutical inspectorate. The most problematic issue is not the law itself but its interpretation. It is necessary to rationalise and standardise the ban on advertising in pharmacies so that entrepreneurs know how to operate in the market and so that their pro-patient initiatives are not blocked. Particularly in a state of emergency, war or natural disaster, it is essential for the patient to be adequately informed about the services available in a given establishment. Currently, the patient is deprived of such information.

    • Speeding up administrative procedures conducted by pharmaceutical inspectorates that prevent pharmacies from opening

    More than 200 pharmacies are currently closed to patients due to suspended operations. In many cases, the prolonged suspension is due to an administrative procedure by a pharmaceutical inspectorate. As a result, the establishment cannot provide its services and stocks medicines that cannot be delivered to patients. In cases where the administrative procedure does not concern matters where the pharmacy endangers patients’ safety or health, there should be a specific time frame for a final administrative decision, which allows the opening of the pharmacy to patients. Currently, there are known cases when administrative procedures, e.g. concerning the transfer of a licence to operate a pharmacy, last even a dozen or more months, while according to the Code of Administrative Court Procedure, they should last two months at most. This results in reduced access to medicines, huge costs for businesses and losses for the State Treasury. In case of a possible crisis or armed conflict, as many establishments as possible should be put into operation. The actions of the pharmaceutical inspectorates should not hinder and cause the prolonged closure of pharmacies that can help patients.

    • Developing ICT systems and official applications to confirm product availability in pharmacies

    To confirm that a particular medicinal product is available in a given establishment, you need to contact the pharmacy directly – in person or by telephone or using a commercial app. Commercial applications only cover selected establishments that have chosen to make information on their stocks available on a paid basis. In recent years, the Polish pharmacy market has been facing the problem of shortages of goods and frequently selected particularly scarce products are available in only a few pharmacies. Introducing a central system indicating a pharmacy convenient to the patient where all the medicines needed are available would be extremely useful.

    1. Drug manufacturing

    In case of a crisis or state of emergency, to ensure continuity in the production of medicines, it is necessary to ensure:

    • the possibility for workers in the domestic pharmaceutical industry to move to work;
    • keeping doctors, pharmacists employed in the domestic pharmaceutical industry in their jobs, fulfilling the obligations of the applicable laws, including but not limited to the pharmaceutical law, so that they are not transferred by the government administration to other tasks;
    • refraining from recruiting pharmaceutical workers in the event of military mobilisation;
    • maximum security of supply chains at the domestic, EU, non-EU and continental levels;
    • in the event of the reintroduction of internal borders within the European Union, the creation of the so-called “medical corridors” for the transport of medicines, active substances and materials necessary for their manufacture;
    • maintaining the mobility of workers within and outside the EU;
    • stopping all legislative work that would worsen the condition of the domestic pharmaceutical industry, including revisions of the Reimbursement Act, and introducing the so-called price corridors if need be;
    • enabling Responsible Persons, Skilled Persons and Competent Persons to work remotely;
    • actively and effectively counteracting speculation on the price of materials necessary for the manufacture of medicines by the institutions set up for this purpose;
    • access for drug manufacturers to the necessary materials for the manufacture of medicines;
    • simplification of procedures and electronic communication in all regulatory and administrative procedures, including the submission of all documents with a certified electronic signature;
    • providing pharmaceutical companies with the opportunity to purchase currency for raw materials for production at the pre-war exchange rate, which will enable the price of medicines to be maintained at its current level;
    • continuity of gas and energy supply to domestic manufacturers.
    1. Waste management

    In providing continuous waste collection and management services (particularly hazardous waste) for both residents and institutions, one of the key issues is securing fuel for the motor vehicles of the services involved in this activity. The massive influx of refugees to Poland also requires additional capacity in plants and waste treatment facilities. Due to delays in the processing (due to the pandemic) of the relevant applications submitted by entrepreneurs, there is a very serious risk that the operations of almost 50% of waste treatment plants and facilities in the country will be unreasonably suspended.

    1. Hospitality and catering

    Amendment of sanitary regulations to facilitate opening accommodation and catering facilities for refugees (hospitality and catering sector).

    1. Metallurgy

    Manufacture of specialised machinery and equipment – metallurgy sector

    • Government-level economic meetings/missions to countries that can support steel supply (Moldova, China, India). Emergency supply agreements are needed.
    • Joint action with the EU on maritime transport to identify priorities for the EU in compliance with WTO rules.
    1. Research and development (R&D)

    Laboratory tests (physical and chemical, microbiological tests, analyses and measurements)

    Recommendations

    Justification

    Applicable regulations

    Accreditation, permits, licences, other applicable regulations

    Renewal of accreditation without periodic evaluation

    Polish Centre for Accreditation (PCA) is a domestic accreditation body authorised to accredit conformity assessment bodies under applicable law.

    No PCA assessment is equivalent to the loss of accreditation for testing/sampling.

    Law regulates the areas where accredited methods are required. In case of difficulties related
    to the PCA operations, the legal possibility of extending the validity of licences already granted seems appropriate.

     

    Act of
    13 April 2016
    on conformity assessment and market surveillance systems (consolidated text of Dz.U./Journal of Laws/ 2022, item 5)

     

    Polish Centre for Accreditation Procedures/Policies

     

    Act of
    27 April 2001 – Environmental Law
    (consolidated text of Journal of Laws of 2021, item 1973).

    Reducing the frequency of testing of the working environment and pollutant emissions/imissions

    The frequency of testing is regulated by law; if the laboratories’ capacity to carry out tests and measurements concerning the working environment and emissions is reduced, it is reasonable to reduce their frequency temporarily.

    Ø Regulation of the Minister of Climate
    and Environment of
    7 September 2021
    on the requirements
    for measuring emission levels
    (Journal of Laws of 2021, item 1710);

     

    Ø Regulation of the Minister of Climate
    and Environment of
    11 December 2020
    on the evaluation of levels of substances in ambient air (Journal of Laws of 2020, item 2279)

     

    Ø Regulation of the Minister of Health
    of 2 February 2011 on tests and measurements of health risk factors in the working environment
    (Journal of Laws of 2011, No. 33,
     item 166).

    Renewal of other permits held by economic operators (e.g. water permits), licences
    (e.g. ones issued by sanitary and epidemiological stations)

    In case of difficulties related to public administration operations, the legal possibility of extending the validity of licences already granted seems appropriate.

     

    Continuity of key services

    Ensuring access to chemical reagents and consumables for key economic operators

    Lack of access to chemical reagents and consumables will result in an inability to provide services to:

    Ø process line entities;

    Ø local government administration, the population
    in the area of testing water for consumption
    and food.

     

     

    Simplification of customs procedures for the purchase of reagents and consumables outside the EU

    In the case of the need to supply essential inputs from outside the European Union, it would seem advisable to simplify customs procedures or even reduce customs duties and fees.

     

    Environmental protection

    Provision of hazardous waste collection

    In case of armed conflict – given the possibility that authorised entities may cease to provide services in this area – takeover of the provision of services relating to the disposal of hazardous waste, including veterinary waste, by municipalities.

    Act of
    14 December 2012
    on Waste
    (consolidated text of Journal of Laws of 2021,
    item 779)

    Energy security

    Ensuring access to electricity for key economic operators

    In case of armed conflict – giving priority to energy consumers who are key economic actors to maintain production continuity.

     

    Finance and taxation

    Simplification and extension of deadlines for the settlement of corporate taxes (CIT, VAT)

     

    Extension of the reporting deadline.

    In case of armed conflict, communication problems with the public administration will affect the ability to settle taxes on time.

    Act of 15 February 1992 on Corporate Income Tax
    (consolidated text of Journal of Laws of 2021,
    item 1800).

     

    1. Sports
    • Keeping activities and procedures to a minimum;
    • Systematic monitoring of the course of actions in Poland and Ukraine (support of services responsible for public security, cooperation of administration bodies, entrepreneurs, groups of companies, etc. support of security divisions);
    • Efficient communication (including crisis communication), defining a list of communication priorities;
    • Designation of alternative venues for major sports activities/meetings/events;
    • Designation of a crisis centre coordinator and responsibilities for individual persons;
    • Creation of a backup of IT resources;
    • Periodic workplace safety procedure refreshers for employees, i.e. information on emergency exits, muster areas, first aid kits, etc.
    1. Glassmaking, glass packaging

    Risks associated with reduced gas supply to the glass packaging industry

    It is necessary to ensure a continuous (uninterrupted) gas supply to the glass packaging industry. A potential interruption of supply, even a short one, can cause irreparable damage and jeopardise safety. 

    1. Potential effects of a natural gas shut-off on the industry
    1. Due to the very high temperatures (approx. 1500°C), the sudden interruption of the operation of glass-melting furnaces as a result of restrictions on the supply of gas poses an immediate danger to the workers’ life and health and also threatens to destroy industrial facilities used in the manufacture of glass.
    2. There are over 40 large and many smaller glass-melting furnaces in operation in Poland. In the largest ones, there are approx. 400 tonnes of liquid glass.
    3. Shutting off the natural gas supply to a glass-melting furnace means:
      – the solidification of liquid glass in the furnace;
       – the irreversible destruction of the entire furnace – the most important part of a glass factory that typically operates continuously for 15 to 20 years.
    4. Due to the nature of the production process and the design of the furnaces required, it is impossible to empty them of liquid glass within a short period (e.g. several hours).
    5. Draining glass from the furnace takes several days, preceded by many days of preparation and constructing a dedicated system.
    6. Bearing in mind the potential scale of the problem (number of systems, availability of ceramic and refractory materials from which the glass-melting furnaces are built and availability of specialist companies), the time for reconstruction of the systems should be counted in years (making a very optimistic assumption that in such conditions the owners will decide to reinvest in them at all).
    1. Potential economic effects
    1. In case of the destruction of most Polish glassmaking facilities, these consequences would potentially affect not only around 20 glass factories but would also result in the dismissal of several thousand workers and the bankruptcy of the owners of these factories.
    2. The associated damage would include months of halting or significantly reducing the production of the food and beverage industries, which are vital to the functioning of the country and life. The number of domestic customers for glass products ranges from a few dozen to more than a hundred per glass manufacturer.
    3. Import substitution of domestic production of glass products destined for other industries must be considered impossible in practice.
    4. The vast majority of recipients of glass products are not in a position to store glass packaging for the manufacture of their products in large quantities – greater than the stock corresponding to their production of a few days.
    5. Poland is the fifth largest producer of glass in Europe. Production is carried out on a very large scale – in the case of container glass, it amounts to approx. 1.8 million tonnes per year and approx. 8.5 billion pieces of glass packaging. 
    6. Polish glassworks also have a positive impact on the balance of trade. A large proportion of the glass industry’s products is sold on foreign markets.
    7. The glass industry also supplies a number of key sectors for the foreign trade balance (e.g. producers of premium spirits, beer, processed foods).
    8. The number of regular suppliers of raw materials, packaging, spare parts for machinery and equipment and specialised services can reach up to 50 per glassworks. Natural and chemical raw materials of domestic origin predominate among the raw materials. The stoppage of production at glassworks also means production cuts and probably a reduction in employment at these suppliers.
    9. Due to the consumption of around 700,000 tonnes per year of recycled raw material (cullet) – keeping glassworks running is crucial not only for the glass recycling industry but for the entire waste management system.

     

    See: 17 March 2022 Business commentary and recommendations on the economic risks associated with the war in Ukraine

    Position of the Union of Entrepreneurs and Employers (ZPP) on Poland becoming independent of Russian supplies of primary commodities

    Posted on by Weronika Marzec

    Warsaw, 28 March 2022 

    Position of the Union of Entrepreneurs and Employers (ZPP) on Poland becoming independent of Russian supplies of primary commodities

     

    Diversification of gas supply is the key to become independent of Russia

    Union of Entrepreneurs and Employers welcomes the announcements about the recapitalisation of investment projects in the gas sector. The development of strategic infrastructure, such as the Świnoujście LNG terminal, the FSRU floating regasification unit in the Gdańsk Bay, or the gas interconnectors with Lithuania and Slovakia, is a solid basis providing technical means for the diversification of gas supply. The above initiative opens us up to new directions for partnership, which, in the long term, will certainly contribute to a reduction in gas prices and, above all, to a complete withdrawal from the Russian supply.

    Forecasts for future years indicate that market demand for natural gas could increase by as much as 50% over the next 10 years. Peak-day gas demand, on the other hand, can periodically increase by up to over 100% compared to previous demand records reported in 2019-2021. In view of the emerging challenges related to the efficient transmission of such a large volume of gas, it is also important to enhance the domestic transmission system.

    Nuclear energy will be an important factor in building energy independence

    Growing concerns about the electricity availability, as well as its cost to the end user, raise legitimate questions about nuclear power. We appreciate the position of the Ministry of Climate and Environment on the need to speed up the construction of nuclear reactors. Nuclear energy will be another element in the optimum structure of the energy mix, which will translate into stability of electricity supply for domestic industry and all households.

    It should be noted that it is not possible to fully replace coal energy with renewable energy sources. Such a solution would be highly risky from the point of view of the stability of the domestic energy system. For this reason, we call for action to be taken as soon as possible to ensure the effective implementation of investments in nuclear energy.

    In our opinion, Poland now has exceptionally favourable political conditions to start building a power plant. In view of the current conflict with Russia, all the EU Member States are looking for ways to become independent of that country’s energy resources. One of the measures most frequently chosen by EU countries is to change their approach to nuclear energy, thereby extending the lifetime of existing nuclear units or expanding the infrastructure with completely new power plants.

    Furthermore, the European Commission’s recent decision on taxonomy, which recognises nuclear and gas energy as transition sources on the road to climate neutrality, should encourage us to invest in nuclear energy. The EC’s modified position allows us to obtain preferential financing for nuclear-based energy projects.

    Unused potential of RES

    New investments in gas and nuclear energy are definitely needed, but they are also highly capital intensive regarding public finances. In our opinion, it is also worth using legal solutions that do not involve any financial burden on the state budget. One action that can be taken immediately by the lawmakers is to amend the so-called anti-windmill law. Liberalising the 10H rule included in this law would contribute to the development of private distributed energy production, requiring little government funding. Energy from onshore wind farms may be the cheapest source of energy, which is important both for individual consumers and for Polish entrepreneurs, for whom energy is an increasing cost of conducting business activities. Such a move would also contribute to the development of Poland’s energy independence – and in a very short period of time, which is why we are calling for this regulation to be changed as soon as possible.

    Embargo on Russian oil

    Contrary to the fears of some commentators, there are many indications that Poland is able to manage without Russian oil supplies. The oil port capacity would more than make it possible to import oil by sea in quantities that would meet Poland’s demand. Meanwhile, supply sources can be successfully diversified. An example of a valuable initiative in this respect is the partnership between PKN Orlen and Saudi Aramco, under which the Saudi company has undertaken to supply between 200 000 and 400 000 barrels of oil per day. In general, there is plenty of oil in the world but, of course, increasing production cannot happen overnight for logistical and technological reasons. According to available data, Polish oil reserves can secure domestic demand for about three months of standard consumption.

    In view of the above, it makes sense to include the embargo on Russian oil in the sanctions imposed on the country. We believe that Poland should take a particularly firm stance on this and urge its European partners to adopt the most far-reaching solutions.

    Conclusions

    The decision to invade Ukraine should be met with a firm stance by the Western world, primarily by isolating the Russian Federation in all areas of international trade, with particular emphasis on the energy industry.

    The Polish Government has accurately defined the areas that require immediate investment to ensure the stability of the domestic energy system, including the country’s energy independence. We would like to draw attention to the additional measures that can be taken without burdening the treasury with further projects. It is also important to respond to these problems with actions that do not further increase the – already very high – producer and consumer inflation.

     

    See: 28 March 2022 Position of the Union of Entrepreneurs and Employers (ZPP) on Poland becoming independent of Russian supplies of primary commodities

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