New businesses and the exemption from transfer pricing analysis
The exemption from transfer pricing analysis in the first year of business raises doubts. Can a new entity benefit from this simplification?
Trademark in Transfer Pricing – how to determine an arm’s length royalty rate?
A shareholder’s trademark used by a company raises questions about the terms of its use and remuneration from a transfer pricing perspective.
New PIT progression and higher CIT. How could taxpayers’ burdens change?
Changes to PIT and CIT may increase the tax burden for some taxpayers. Who will benefit from the new thresholds, and who will pay more after the tax reform?
SAF-T for CIT: Proposed postponement of JPK_ST_KR fixed asset reporting
The Ministry of Finance and Economy has prepared a draft regulation providing for an exemption from JPK_ST_KR reporting for the years 2026–2028.
Does aligning cost base always constitute a transfer pricing adjustment under Article 11e?
For several years, the answer to this question has been subject to debate, as evidenced by the numerous requests for individual tax rulings in Poland submitted by taxpayers. Some case law and tax ruling practice indicated that, where only the cost base changes under a cost-plus model, while the mark-up percentage remains unchanged and there…
Public CbC-R – a report that requires decisions, not just data
Public CbCR is becoming mandatory for the largest corporate groups. What do the new rules mean for reporting and risk management?
Excise duty exemption for products containing denatured alcohol – significant EU General Court judgment T-381/25
EU Court on the excise duty exemption for denatured alcohol. What does the ruling mean for manufacturers of industrial products?
Coca-Cola vs IRS – does a long-standing transfer pricing model really provide protection?
Does the Coca-Cola dispute with the IRS show that years without objections from the tax authorities do not necessarily guarantee tax certainty?
Robotization Tax Relief: What constitutes an industrial application of a robot?
The fundamental condition for claiming the robotization tax relief is that the acquired equipment must possess the characteristics required to qualify as an industrial robot within the meaning of the tax legislation.
Do Polish and foreign self-balancing branches have to report JPK_CIT?
The KIS’s revised 2026 approach reduced the risk of double bookkeeping and excessive JPK_CIT obligations for foreign branches.