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…
The year 2024 has not introduced any major changes to transfer pricing regulations. However, related parties must still carefully comply with documentation and reporting obligations for intra-group transactions made in 2023. The process begins with identifying relationships as defined by transfer pricing regulations. The next step is determining whether the transactions qualify as controlled transactions…
The Ministry of Finance, following the example of previous regulations issued during the pandemic and in support of victims of the armed conflict in Ukraine, prepared a regulation introducing a temporary 0% VAT rate for free-of-charge supplies of goods and services aimed at supporting flood victims. The possible legal path of a regulation allowing for…
Transfer Pricing: who has documentation and reporting obligations? If: you are a taxable person (subject to corporate income tax or personal income tax), and in 2023, you engaged in transactions with related parties, and the value of these transactions exceeded the statutory thresholds in 2023, then you need to determine your transfer pricing obligations…