From the very beginning of 2023, Poland will allow a group of entities bound by financial, economic and organisational links to be registered as a one taxpayer, i.e. the VAT group. It may be a suitable solution to eliminate output VAT in the intra-group transactions, but the complexity of regulations regarding input VAT deduction and…
Monika Dziedzic and Paweł Wyciślik of MDDP report on the most significant changes under an amendment to the Polish Corporate Income Tax Act. In January 2023, an amendment to the Polish Corporate Income Tax Act will come into force. Pro-fiscal changes as well as solutions that are favourable for taxpayers will be introduced, making certain…
Deadlines for meeting transfer pricing obligations for 2021 are looming. Less than 2 months are left until 31 December. Just like every year, there are quite a lot of formalities to be completed. Those who have not yet prepared documents for 2021: we have summarized the obligations you must meet. Every week we will remind…
From 1 January 2021, specific CIT taxpayers may choose the form of their income taxation: they may settle on general principles (already known) or opt for a new simplified form of taxation, i.e. the lump sum on the income of companies (the so-called Estonian CIT). What is the difference? In a regular CIT, the taxation…
We have some good news for taxpayers right before the end of the year and the beginning of intensive works on documenting and reporting transactions with related parties and tax haven entities. On 21 October (Friday), the third version of the TPR-C Guidebook was published on the Ministry of Finance’s website. It supplements and extends…
In the ruling no. I SA/Gl 233/22 of 31 August 2022, the District Administrative Court in Gliwice repealed the decision of the Head of the Silesian Customs and Tax Office in Katowice on the reduction of CIT in 2016. The case concerned the acquisition and lease of trademarks from a related entity where the costs…
On 13 October 2022, the amendment to the Commercial Companies Code entered into force[1]. It introduced provisions on the group of companies, including a new instrument: binding instructions. According to the new provisions of the holding law, the parent company may issue a binding instruction to a subsidiary in order to pursue the common interest…
Transfer pricing continues to attract the attention of tax authorities. Major additional income assessments and successfully completed controls (from the perspective of tax authorities) are summarized by the National Revenue Administration – it releases information on the amount of the additional assessment and the exact scope of the control. Last week saw two of such…
On 13 July 2022, the National Working Group (NGR) for reform of reference index was established. It was tasked with introducing a new interest rate reference index in place of WIBOR. The NGR features, among others, the representatives of te Ministry of Finance, the Bank Guarantee Fund (BFG), the Polish Development Fund (PFR), Warsaw Stock…
Magdalena Dymkowska of MDDP provides a guide to the vagaries of the Polish transfer pricing regulations and explains why the applicability of the arm’s-length rule may leave multinational companies somewhat surprised. Multinational companies that are familiar with transfer pricing (TP) issues in their countries might raise their eyebrows over the kinds of transactions that are…