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…
What is Local File documentation? Transfer pricing documentation is a legally required document focused on intra-group transactions. You must prepare the Local File documentation when engaging in controlled transactions with related entities. Typically, it is required when the value of such transactions exceeds the financial thresholds set by regulations within the tax year. The statutory…
Admittedly, this is only to apply to property tax returns and will require taxpayers to submit a declaration to the tax authorities, but it is worth appreciating the opportunity provided by the latest draft amendment to the Local Taxes and Fees Act. Why such an opportunity? The circumstance is related to the new definitions of…