In 2025, WHT taxpayers will face some changes – among them, we will find new versions of the IFT-2R and CIT-10Z forms, concerning the foreign income of taxpayers earned from January 1, 2024. Comparing the new structure of the forms with the previous version will certainly make it easier to complete them, especially since many…
According to the presidential memorandum (dated January 20, 2025) directed to the Secretary of the Treasury and the U.S. Permanent Representative to the OECD, the United States is withdrawing from the Global Tax Deal. Therefore, the GloBE system will not apply in the United States. Does this mean that the GloBE system is no longer…
The Act of 6 November 2024 on Top-up Taxation of Constituent Entities of Multinational and Domestic Groups [GloBE Act] introduces a tax regime of minimum taxation of at least 15% of all group entities in one jurisdiction. Under the GloBE Act, constituent entities of domestic and multinational enterprise [MNE] groups – with consolidated revenues exceeding…
A number of significant and, in some cases, even revolutionary changes introduced in the tax legislation from 2025 require taxpayers to prepare carefully for their proper implementation. Particular attention is required to review the fixed asset records for real estate tax declarations and to adapt their classification to the new definitions. Taxpayers should also adapt…
The new Notice of the Minister of Finance on the announcement of the type of base interest rate and margin for transfer pricing (safe harbor for financial transactions) has been published! Conditions for safe harbor in financial transactions The Finance Minister has updated the conditions authorizing the use of safe harbor simplification for financial transactions.…
Does a taxpayer retain the right to deduct when input VAT results from services provided by one of the group companies to both the taxpayer seeking to deduct and the other group members? This issue has been resolved by the CJEU in its judgment of December 12th, 2024, ref. C-527/23. Facts The case concerned the…
Many companies aim to strengthen their relationship with with their employees by offering various employee benefits or facilities. One of the increasingly popular option is the opportunity to purchase used equipment at attractive prices, such as computers, laptops or smartphones. While such offers can be beneficial for both employees and employers, it is essential to…
The festive period is a time when many employers decide to give Christmas gifts to their employees. However, it is worth bearing in mind that these gifts may have certain tax implications. When is a gift to an employee taxable and when not? What limits are worth bearing in mind and can the costs of…
Investing in the renewable energy sector requires careful evaluation of the financing options available. A critical element of this process is assessing the tax implications of each potential financing method. Let’s explore the tax implications associated with the most common methods of financing of renewable energy projects. Intra-group financing through loans Capital groups often use…
Discover how to create a step-by-step transfer pricing policy designed to minimize and compliance and tax risks for your business. What is a transfer pricing policy? A transfer pricing policy outlines the rules for determining prices in transactions between related parties, ensuring they meet the arm’s length standard. This policy is essential for companies operating…