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MDDP – TAX ADVISORY
MDDP - TAX ADVISORY
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Does aligning cost base always constitute a transfer pricing adjustment under Article 11e?

Does aligning cost base always constitute a transfer pricing adjustment under Article 11e?

Transfer pricingBy MDDP17 August 2026

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 CbC-R – a report that requires decisions, not just data

Transfer pricingBy Marta Klepacz10 August 2026

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

Excise duty exemption for products containing denatured alcohol – significant EU General Court judgment T-381/25

INSIGHT, Trochę o VAT, VATBy Katarzyna Trzaska-Matusiak7 August 2026

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?

Coca-Cola vs IRS – does a long-standing transfer pricing model really provide protection?

Transfer pricingBy Marta Klepacz3 August 2026

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?

INSIGHT, Trochę o CITBy Bartosz Glowacki17 July 2026

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?

Do Polish and foreign self-balancing branches have to report JPK_CIT?

Corporate tax, INSIGHT, Trochę o CITBy Anna Zielony14 July 2026

The KIS’s revised 2026 approach reduced the risk of double bookkeeping and excessive JPK_CIT obligations for foreign branches.

Joint and several liability of a tax representative – judgment of the General Court of the European Union

Joint and several liability of a tax representative – judgment of the General Court of the European Union

INSIGHT, Trochę o VAT, VATBy Aleksandra Orzechowska14 July 2026

CJEU judgment in Case T-356/25 Rapera: is a tax representative jointly liable for VAT when they only file returns and make tax payments?

Transfer pricing in 2026 – Local File, TPR and Master File deadlines for FY 2025

Transfer pricing in 2026 – Local File, TPR and Master File deadlines for FY 2025

Transfer pricingBy MDDP13 July 2026

Although transfer pricing deadlines are a permanent feature of the tax calendar, they still tend to surprise taxpayers each year. However, documentation obligations can be planned well in advance. For this reason, related parties should ensure timely verification of their controlled transactions, applicable documentation thresholds, and available exemptions.

KSeF 2026 – the 5 most common mistakes in structured invoicing and how to avoid them

KSeF 2026 – the 5 most common mistakes in structured invoicing and how to avoid them

INSIGHT, Trochę o VAT, VATBy Janina Fornalik2 July 2026

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 EU Tax Omnibus proposes: fewer formalities, broader exemptions and new incentives for investment

The EU Tax Omnibus proposes: fewer formalities, broader exemptions and new incentives for investment

Corporate tax, INSIGHT, Trochę o CITBy Radosław Nowak29 June 2026

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.

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