Joint and several liability of a tax representative – judgment of the General Court of the European Union
CJEU judgment in Case T-356/25 Rapera: is a tax representative jointly liable for VAT when they only file returns and make tax payments?
Transfer pricing in 2026 – Local File, TPR and Master File deadlines for FY 2025
Although transfer pricing deadlines are a permanent feature of the tax calendar, they still tend to surprise taxpayers each year. However, documentation obligations can be planned well in advance. For this reason, related parties should ensure timely verification of their controlled transactions, applicable documentation thresholds, and available exemptions.
KSeF 2026 – the 5 most common mistakes in structured invoicing and how to avoid them
The mandatory National e-Invoicing System (KSeF) fundamentally changes the way transactions between businesses are documented. We outline five key areas that deserve particular attention.
The EU Tax Omnibus proposes: fewer formalities, broader exemptions and new incentives for investment
The European Commission has presented a draft directive referred to as the tax Omnibus package. Its main objective is to simplify EU rules on direct taxation, reduce administrative costs for businesses and tax authorities, and strengthen the competitiveness of the internal market.
IP Box and transfer pricing – where do these two worlds meet?
How to correctly determine the income covered by IP Box, and where do transfer pricing rules come into play in this process?
CIT exemption for foreign investment funds investing in Polish real estate – key court rulings and practical implications
New CIT rulings strengthen tax certainty for foreign funds and make Poland more attractive to real estate investors.
Exemption of cross-border dividends from withholding tax in light of the latest signals from the CJEU
WHT audits are intensifying, and WHT on dividends paid to foreign entities has become a major dispute area between tax authorities and business.
NSA on share valuation: criticizing the method alone is not enough
The judgment of the Polish Supreme Administrative Court (NSA): a tax authority cannot automatically challenge a transaction price simply because it disagrees with the valuation method applied. When questioning the arm’s length nature of a transaction, the authority must demonstrate far more than mere reservations regarding the adopted methodology.
TP Statement and non-arm’s length transfer prices – does a CIT adjustment eliminate the risk?
Can a taxpayer confirm in the TPR form that its transfer prices were arm’s length if it has previously adjusted its taxable income to an arm’s length level? A recent judgment of the Voivodeship Administrative Court in Gliwice suggests that a mere adjustment of the CIT settlement does not determine whether the conditions of a…
Free-of-charge share redemption and transfer pricing consequences – recent Polish Supreme Administrative Court rulings
The Supreme Administrative Court (SAC) is increasingly indicating that certain capital transfers may also constitute a controlled transaction within the meaning of transfer pricing regulations. Such an approach also applies to arrangements that were previously often regarded as tax-neutral, including the free-of-charge share redemption. In practice, this may entail an obligation to conduct a thorough…