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…
Entrepreneurs operating in the IT industry can benefit from a wide range of tax reliefs and preferences aimed at supporting innovation and technological development. It is not surprising that so many solutions are dedicated to this fast-growing industry, given its key role in creating cutting-edge solutions for companies. Among the most popular tax instruments available…
Virtual items, such as skins available in computer games, have become a popular subject of trade on the Internet. The sale of these goods, although seemingly unrealistic, is nevertheless subject to actual tax rules. In this post, we explain how to correctly settle the income from such sales. Sales as a business activity The sale…
A few words about the CJEU ruling on November 21st, 2024, ref. C-624/23, SEM Remont. Case overview The ruling was issued in connection with a transaction in which, in August 2020, the Bulgarian company SEM Remont contracted the Russian company Gidrostroy – Russia to carry out dredging works in the port of Varna. The contractor,…
In recent days, the Ministry of Finance has published two general rulings relating to some of the conditions for the exemption from withholding tax of dividend and interest payments. These rulings are important, but are they groundbreaking? How will the existing practice of the authorities and courts change? In the first part, we are going…