IMPEL SA (35/2018) Receipt by the Issuer's subsidiary company of the result of control carried out by the Head of the Lower Silesian Customs and Tax Office

Today (ie November 8, 2018) the Issuer's subsidiary, i.e. Hospital Service Company Sp. z o.o. spółka komardytowa (Company) served with the result of the audit (No. 452000-CKK-51.500.30.2017.70) of the Head of the Lower Silesian Customs and Tax Office in Wrocław (& quot; UCS & quot;) regarding the reliability of the declared tax bases and the correctness of calculating and paying the tax on goods and services for the period from January to December 2015 (& quot; Control result & quot;). & Lt; br / & gt; & Lt; br / & gt; The result of the inspection, prepared on the basis of art. 82 par. 1 of the Act of November 16, 2016 on the National Tax Administration, was issued in the course of customs and tax control kept by UCS. & Lt; br / & gt; & Lt; br / & gt; The audit result indicated irregularities in the VAT settlement, resulting in its understatement in the amount of PLN 28,230 thousand. zł. According to UCS, they result from the improper application of the exemption from VAT, in relation to the services provided to medical entities in which the medical activity is performed. & Lt; br / & gt; & Lt; br / & gt; In the Company's opinion, the VAT exemption was applied correctly, because the Company has the status of a medical entity, and the services provided by the Company meet the statutory requirements for VAT exemption and, in particular, they serve to prevent, preserve, rescue, restore and improve health. In the assessment of the Company, the Authority did not take into account the fact that the VAT exemption of services provided by the Company was subject to the interpretation of individual tax law, issued to the Company in 2012. In the said interpretation, the Minister of Finance confirmed the right of the Company to use the VAT exemption, therefore, in accordance with the provisions of the Tax Code, the Company enjoys interpretative protection, manifesting itself, inter alia, in the lack of the possibility to establish tax arrears on the part of the Company in this regard. & Lt; br / & gt; & Lt; br / & gt; In addition, it should be pointed out that in the same facts, in terms of VAT for 2014, the decision of the Director of the Tax Administration Chamber in Wrocław of 19/04/2018 (No. 0201-IOV1.4103.181.2017) was issued confirming the correctness of tax settlements. Companies in the field of VAT. & Lt; br / & gt; & Lt; br / & gt; The company does not agree with the findings contained in the Audit Result, and therefore does not intend to exercise the right to submit the correction of tax declarations in accordance withthe content of the findings of the Audit result. The decision is not final, because the control will then turn into a tax procedure. & Lt; br / & gt; Legal basis: & lt; br / & gt; Article 17 para. 1 MAR - confidential information. & Lt; br / & gt;

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Company information
Company name:Impel SA
Adress: ul. Ślężna 118 53-111 Wrocław
Phone:+48 71 7110000

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