Leeds credit lender to appeal decision of Polish Tax Chamber

LEEDS-based credit lender International Personal Finance said this morning that its home credit company in Poland, Provident Polska, is to appeal a decision received from the Polish Tax Chamber, the upper tier of the Polish tax authority, with respect to its 2008 financial year.

The decision involves a transfer pricing challenge relating to an intra-group arrangement with a UK entity together with a challenge to the timing of taxation of home collection fee revenues.

IPF said: “We strongly disagree with the interpretation of the tax authority having received legal opinions from leading advisors as to the strength of our case. In addition, during a previous tax audit by the same tax authority, both items were challenged and the company’s treatment of them was accepted as correct. Provident Polska’s treatment of these items has not changed since then.

“We will appeal the decision to the District Administrative Court and pay the amounts assessed (around £20m comprising tax and associated interest) which is necessary in order to make the appeal. The payment of this sum is not a reflection of our view on the merits of the case and accordingly it will be recognised as a non-current financial asset in our group accounts.”

The group said that, as it believed its case to be “very strong,” no provision will be recognised against this asset and there will be no charge to the income statement as a result of the decision.

It added: “We also intend to initiate a process with the UK tax authority aimed at ensuring that the intra-group transaction is not subject to double taxation but is taxed in accordance with international tax principles.

“We expect to receive the same decision shortly from the Polish Tax Chamber in respect of the 2009 financial year which would give rise to a substantially similar liability to that for 2008. 2010 remains under audit and all subsequent years remain open to future audit.”