As of January 1, 2025, amendments to the thermomodernisation tax relief have come into effect, which may impact the tax settlements of individuals investing in energy-efficient building improvements. The new regulations eliminate the possibility of deducting certain expenses, such as those related to gas or oil boilers, while expanding the relief to cover new categories…
The deadline for submitting the CbC-P notification for 2024 to the Head of the National Revenue Administration (KAS) is fast approaching—31 March 2025 (for entities whose financial year aligns with the calendar year). This obligation applies to entities that are part of corporate groups required to submit a Country-by-Country Report (CbC-R). What is CbC-P reporting?…
The introduction of the domestic minimum top-up tax into Polish legal system is associated with the entry into force of the Act of 6 November 2024 (GloBE Act) on the top-up taxation for constituent entities of multinational and domestic groups. The GloBE Act introduces a regime for top-up taxation (at a minimum rate of 15%)…
The Act of 6 November 2024 on the top-up taxation of constituent entities of multinational and domestic groups (GloBE Act) introduces a global minimum tax system (at least 15%) at the jurisdiction level. Under the GloBE Act, entities belonging to multinational and domestic groups – with consolidated revenues exceeding €750 million in at least 2…
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…