Any person who, in a given tax year, sold or purchased cryptocurrencies (more precisely, virtual currencies) should report the income earned or the deductible costs incurred in the annual PIT-38 return. The deadline for filing the PIT-38 return is 30 April of the following year. This obligation also applies to investors who, in a given…
Informal group decision and transfer pricing: risk, lack of remuneration and tax authority approach in case law
A transfer pricing audit helps identify tax risks, organise intra-group settlements and better prepare a company for potential tax audits.
The Public CbC-R in Poland, effective from 2026, introduces the obligation for companies to publicly disclose their financial and tax data, with the option to protect sensitive information.
The condition of beneficial ownership has remained one of the key issues in withholding tax for many years, particularly in the context of applying exemptions provided for in the CIT Act. The legislator explicitly made the exemption from withholding tax on royalties and interest conditional upon beneficial ownership. In practice, however, tax authorities tend to…
Personal links and the TP documentation exemption – when Article 11n(5) of the CIT Act applies and what risks arise from KIS practice and court case law.
Companies with a shifted financial year – check your transfer pricing obligations. TP audit, documentation, TPR, and Master File, including for foreign entities.
The deadline for CBC-P for 2025 is 31 March 2026; check who is required to file, what data must be reported, and the applicable sanctions.
Transfer pricing adjustments as a tool for restoring arm’s length conditions. Legal requirements, tax risks, VAT implications and Polish practice.
Eligible costs under the research and development (R&D) tax relief include, among others, expenses incurred on the remuneration of employees performing R&D activities. These expenses may be deducted to the extent that the time devoted to R&D activities remains in proportion to the employee’s total working time in a given month. Moreover, the concept of…