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If the decision on the payment of the profit is made before the transformation of the sole proprietorship, the payment of profits by the LLC (the transformed company), generated by this sole proprietorship and previously taxed, does not generate income subject to taxation (PIT). In this case, the assets of the sole proprietorship, which will be allocated for payment, should not be interpreted as assets of the private limited company established after the transformation.

KIS interpretation of 14/03/2022 (0114-KDIP3-1.4011.1151.2021.1.MG).