Alupol Packaging S.A. and Alupol Films sp. z o.o. (Flexible Packaging Segment) operate in Special Economic Zones on the basis of permits. Moreover, in 2021, Grupa Kęty S.A. and Romb S.A. received decisions on aid for new investment projects. Therefore, as regards their income from the operations defined in the relevant permits/decisions, the companies may take advantage of corporate income tax exemptions, upon fulfilment of the conditions specified in the permits/decisions. The maximum level of exemptions (state aid limit) depends on the amount of eligible capital expenditure made under each permit/aid decision. The zone operation permits held by the Group and the periods of tax exemptions availing expire on 31 December 2026, whereas the aid decisions expire in 2031 and 2033, respectively. In order to estimate the value of the possible benefits of the permits/aid decisions related to operation in the relevant areas/Special Economic Zones, an assumption has been made compliant with the gross profit level on the said investment projects presented in the Group 2025 Strategy, corrected for the major temporary differences (differences between the value of tax depreciation and balance-sheet depreciation). As regards the decisions for which the exemption conditions have not yet been fulfilled, the Group estimates their performance based on proprietary projections.
The table below presents the amounts of available discounted state aid (state aid limit):
|
The amounts of available discounted state aid (state aid limit) |
31.12.2021 | 31.12.2020 |
| Permits expiring on 31 December 2026 – aid limit of 40% | 48,638 | 48,638 |
| Permits expiring on 31 December 2026 – aid limit of 35% | 81,279 | 81,279 |
| Aid decisions expiring in 2023 – aid limit of 35% | 132 | 0 |
| Aid decisions expiring in 2031 – aid limit of 25% | 447 | 0 |
| Total | 130,496 | 129,917 |
In accordance with the applicable regulations, the state aid limit is determined based on discounted expenditures on the purchase of property, plant and equipment under the permits/aid decisions obtained. The discount is made as at the date of the permit issue, based on the discount rate announced by the Office for Competition and Consumer Protection.
The table below presents the amounts of the discounted state aid utilised starting from the permit issue date:
| The amounts of the discounted state aid availed of | 31.12.2021 | 31.12.2020 |
| Permits expiring on 31 December 2026 – aid limit of 40% | 48,638 | 39,757 |
| Permits expiring on 31 December 2026 – aid limit of 35% | 50,436 | 26,776 |
| Total | 99,074 | 66,53 |
In accordance with the applicable regulations, the nominal amounts of tax exemptions obtained are discounted as at the date of the permit issue, under which the settlement is made, with the use of the discount rate announced by the Office for Competition and Consumer Protection. Such discounted amounts may not exceed the state aid limits.
The table below presents the nominal value of state aid availed of:
|
The nominal value of state aid availed of (value of the utilised tax exemptions) |
31.12.2021 | 31.12.2020 |
| Permits expiring on 31 December 2026 – aid limit of 40% | 61,580 | 50,536 |
| Permits expiring on 31 December 2026 – aid limit of 35% | 59,312 | 30,975 |
| Total | 120,892 | 81,511 |
The table below presents the planned use of deferred tax assets resulting from operations in Special Economic Zones, broken down into the particular years.
|
Value of assets broken down into the expected periods of use |
31.12.2021 | 31.12.2020 |
| Year 2021 | 0 | 21,430 |
| Year 2022 | 18,813 | 10,608 |
| Year 2023 | 19,332 | 11,006 |
| Year 2024 | 186 | 11,439 |
| Year 2025 | 0 | 11,660 |
| Year 2026 | 0 | 11,611 |
| Total | 38,331 | 77,754 |
