For years, financial, service, and distribution or production transactions have consistently been the most commonly reported in the TPR form. This is largely because they are easy to identify as subject to transfer pricing regulations. However, in a complex and rapidly evolving business environment, companies often engage in transactions that do not fit neatly into…
The Head of the National Revenue Administration [KAS] has refused to issue letter of practice regarding incentive programs (ref. DKP16.8082.4.2024 and DKP16.8082.7.2024). This decision raises questions about the tax security of such solutions and potential risks for companies implementing incentive schemes. Which incentive programs were challenged by the Head of KAS? In both cases, the…
Intangible services have long been a focus of tax authorities. It is therefore essential to understand the key risk areas associated with these service costs and to manage them proactively throughout the year—not just when preparing transfer pricing documentation. Confirmation of service performance (Benefit Test) When it comes to intangible services, taxpayers must be able…
Companies are increasingly investing in sustainable development. Green innovations not only help protect the environment but also bring tangible business benefits. One of the tools supporting companies in this transformation is the Research and Development (R&D) tax relief, which allows for additional deductions of specific expenses from the tax base. What is the R&D tax…
The approaching deadline for PIT settlements for 2024 poses a serious challenge for many taxpayers regarding how to correctly settle their income, especially foreign income when it comes from investments through foreign banks. This topic becomes particularly important for people who have investments in foreign banks (e.g. Switzerland, Germany, Austria, France, USA) and invest through…
The list of countries that have obtained “qualified” status for GloBE purposes is now known. The Ministry of Finance published an announcement on February 7, 2025, regarding the list of non-Polish jurisdictions that have implemented a qualified income inclusion rule or a qualified domestic minimum top-up tax or meet the requirements for safe harbors for…
Transactions with related parties can pose significant tax risks. Many taxpayers only identify transfer pricing (TP) issues when preparing documentation and submitting the Transfer Pricing Report (TPR), at which point their ability to implement necessary corrections is limited. A financial audit presents an excellent opportunity to proactively identify risks related to intra-group transactions. As part…
In a few days, the deadline for submitting important declarations by entrepreneurs will pass. Individuals running sole proprietorships and partners in certain types of partnerships are faced with the decision of choosing the optimal solution, which could result in tax savings throughout 2025. Forms of taxation for incomes generated by entrepreneurs or partners in selected…
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?…