The mandatory National e-Invoicing System (KSeF) fundamentally changes the way transactions between businesses are documented. We outline five key areas that deserve particular attention.
The European Commission has presented a draft directive referred to as the tax Omnibus package. Its main objective is to simplify EU rules on direct taxation, reduce administrative costs for businesses and tax authorities, and strengthen the competitiveness of the internal market.
How to correctly determine the income covered by IP Box, and where do transfer pricing rules come into play in this process?
New CIT rulings strengthen tax certainty for foreign funds and make Poland more attractive to real estate investors.
WHT audits are intensifying, and WHT on dividends paid to foreign entities has become a major dispute area between tax authorities and business.
The judgment of the Polish Supreme Administrative Court (NSA): a tax authority cannot automatically challenge a transaction price simply because it disagrees with the valuation method applied. When questioning the arm’s length nature of a transaction, the authority must demonstrate far more than mere reservations regarding the adopted methodology.
Can a taxpayer confirm in the TPR form that its transfer prices were arm’s length if it has previously adjusted its taxable income to an arm’s length level? A recent judgment of the Voivodeship Administrative Court in Gliwice suggests that a mere adjustment of the CIT settlement does not determine whether the conditions of a…
The Supreme Administrative Court (SAC) is increasingly indicating that certain capital transfers may also constitute a controlled transaction within the meaning of transfer pricing regulations. Such an approach also applies to arrangements that were previously often regarded as tax-neutral, including the free-of-charge share redemption. In practice, this may entail an obligation to conduct a thorough…
Should the robotics relief be settled together with depreciation, or as a one-off deduction? Diverging interpretations raise doubts regarding the treatment of eligible costs.
Transactions carried out between companies and members of the management board are, in themselves, neither unusual nor uncommon in business practice. Nevertheless, in order to avoid such transactions being challenged by the tax authorities, both the commercial rationale for such arrangements and their terms should be carefully analysed from a tax perspective.