As a rule, the tax year for minimum tax is the calendar year. The legislation also allows taxpayers to amend this period depending on the decision expressed, inter alia, in the company’s articles of association. However, even in this situation, the tax year generally comprises twelve consecutive calendar months. In certain circumstances, this period may…
On October 4, 2024, the Court of Justice of the European Union (CJEU) delivered a judgment in the Voestalpine Giesserei Linz case (C-475/23), addressing the right to deduct VAT related to the acquisition of a machine provided free of charge to a subcontractor under a tooling agreement. The judgment pertains to a common practice, especially…
In a tax ruling dated 16 September 2024, ref. 0111-KDIB1-2.4010.340.2024.1.BD, it has been ruled that the income of a family foundation from the sale of cryptocurrencies is not exempt from corporate income tax but is taxed at a corporate income tax rate of 25%. Story A family foundation wanted to invest its assets in cryptocurrencies.The…
The deadlines for meeting transfer pricing obligations for 2023 are fast approaching, especially for taxpayers whose fiscal year aligns with the calendar year: by October 31, local transfer pricing documentation must be prepared. by November 30, transfer pricing information must be submitted using form TPR-C. In this post, we address common questions surrounding the submission…
On 5 October, the Act of 1 October 2024 amending the Act on special solutions related to flood recovery and certain other acts [Amendment Act] entered into force. Donations for flood relief with no impact on minimum income tax Newly introduced article 1(25) of the Amendment Act provides that for the purposes of calculating the…
On Monday 7 October 2024, a draft law amending the Agricultural Tax Act, the Local Taxes and Fees Act and the Stamp Duty Act was submitted to the Council of Ministers for deliberation. It is a proposal for new legislation on several tax laws, developed during extensive public consultations, but which will most profoundly affect…
Technology, and in particular tools using artificial intelligence (AI) and cloud solutions, have already begun to revolutionise the market, and their development promises even more profound changes. From legal and tax projects to day-to-day business operations, the future will bring with it exciting opportunities to increase efficiency, save costs and improve customer satisfaction. Key Developments…
The Administrative Court in Gliwice ruled in a judgment of 24 June 2024 (ref. I SA/Gl 1679/23) that the performance of remote work by an employee of a foreign company in Poland does not create a permanent establishment of a foreign company in Poland. The judgement is not final. Background A German company was set…
A comparative analysis, also referred to as a transfer pricing benchmark, is essential for: establishing transfer pricing in the arm’s length range, and fulfilling documentation requirements. How and why to perform a transfer pricing benchmarking? We conduct the analysis by comparing the prices charged (or the results achieved) in transactions between related parties with those…
The sale of alcohol, including wine, between EU countries comes with obligations regarding excise duties and VAT. Currently, the Court of Justice of the European Union (CJEU) is reviewing case C-596/23 (Pohjanri), which could impact business models and pricing policies due to the scope of excise taxation. On September 26, 2024, Advocate General Priit Pikamäe…