Current Report No. 31/2024Date: 2 October 2024Topic: Judgment ofthe Supreme Administrative Court concerning the individualinterpretation of the Director of the National Revenue Informationregarding value added taxLegal basis: Article 17(1) MAR - InsideinformationContent:In reference to current report no.5/2020 of 1 April 2020 and current report no. 6/2020 of 1 April 2020concerning the recognition of a provision for potential liabilityresulting from VAT in the subsidiary IRGiT, the Management Board of GPWS.A. ("GPW", "Company") announces that a hearing was held today beforethe Supreme Administrative Court to consider IRGiT's appeal on a pointof law against the judgment of the Regional Administrative Courtconcerning the individual interpretation of the Director of the NationalRevenue Information regarding value added tax.The SupremeAdministrative Court adjourned the proceedings and issued a decision torefer a question for a preliminary ruling to the Court of Justice of theEuropean Union. In the question referred for a preliminary ruling, theSupreme Administrative Court requested the Court of Justice of theEuropean Union to resolve on the compatibility with Directive2006/112/EC of Article 86(10b)(1) of the Value Added Tax Act whichprovides that a taxpayer is entitled to deduct input VAT on atransaction to buy goods or services not earlier than in the tax month(period) in which the taxpayer receives the invoice documenting thetransaction, or whether the taxpayer is entitled to deduct input VAT inthe tax month (period) in which the taxpayer meets the substantiveconditions of exercising this right while the taxpayer receives theinvoice after the end of such period but before the time limit for thesubmission of the tax return for that month.

The decision, in the opinion of the GPW Management Board, does notchange the assessment of the Company's financial position, in particularthe amount of the recognised provision.

Legal basis: Article 17(1) of Regulation (UE) No. 596/2014 of theEuropean Parliament and of the Council of 16 April 2014 on market abuse(market abuse regulation) and repealing Directive 2003/6/EC of theEuropean Parliament and of the Council and Commission Directives2003/124/EC, 2003/125/EC and 2004/72/EC (Official Journal L 173) ("MAR")