The Court of Justice of the European Union has, for the first time, ruled in a case directly addressing the VAT implications of transfer pricing adjustments (Case C-603/24 Stellantis Portugal). This is a highly significant and controversial issue across the EU due to the absence of a harmonised approach among Member States.
A taxpayer who has not received payment for goods or services supplied may – subject to certain conditions – benefit from a bad debt relief, i.e. to reduce the output VAT previously paid to the tax authorities (Article 89a of the VAT Act). However, as confirmed by the Court in case T-233/25 Mokoryte, this possibility…
Transfer pricing documentation within multinational capital groups has become an invaluable tool not only in the context of transfer pricing verification, but also in relation to other taxes, including withholding tax (WHT). In Poland, tax authorities are increasingly referring to group documentation, namely the Master File, during WHT audits.
Recently, there has been a lot of discussion about the Act amending the Act on the State Labour Inspection and certain other acts, which was signed by the President of the Republic of Poland. Understandably, in cases where a B2B contract is reclassified as an employment contract, the focus is primarily on the risks related…
According to the current position of tax authorities and administrative courts, the tax base for the solidarity levy can be reduced by tax losses from previous years. However, it should be noted that the deduction of tax losses is only possible within the same source of income. Solidarity Levy The solidarity levy has been…
More and more Poles are deciding to work remotely for foreign companies. Sometimes this means physical travel and daily work outside the country, but just as often the work is done in Poland and professional duties are performed from a home office, co-working space or even a café – for employers in Germany, the Netherlands,…
Transfer pricing benchmarks under judicial scrutiny. Key insights from recent international case law and their implications for taxpayers.
Persons who earn income from abroad – for example, from interest or dividends – must declare this tax themselves in their annual PIT return. It often happens that tax has already been deducted at source from such payments abroad. The amount depends on the country of payment. In practice, the tax paid abroad is often…
April is the last month to file your 2025 PIT return. Although basic tax reliefs, such as the child tax relief or the thermomodernisation tax relief, are widely known and often used, there are other preferences that not everyone has heard of. In this article, we will present less popular tax allowances that will help…
Deferred payments in related-party transactions may undermine arm’s length conditions and lead to income adjustments by tax authorities