General rules The regulations on preventing hybrid mismatches in Poland came into force on January 1, 2021, and are an implementation of the EU ATAD 2 directive. Analogous regulations are in force in other EU countries, as well as outside the bloc (the UK, Australia). The purpose of the regulations is to prevent double deduction…
On January 1, 2024, the minimum corporate income tax provisions of Article 24ca of the CIT Law will begin to apply. Therefore, we are starting a series of publications in which we will introduce the assumptions of minimum income tax and indicate how to determine whether it will apply to a particular organization and, ultimately,…
In 2023, the deadlines for completing transfer pricing obligations for 2022 have been shortened. The starting point for fulfillment of TP obligations is reliable local documentation (Local File). Deadline for fulfillment of obligations For taxpayers whose tax year coincides with the calendar year, the deadline for Local File for 2022 is October 31, 2023. Admittedly,…
The consultation period for draft withholding tax guidelines could be crucial in addressing the issues surrounding their potential application, say Monika Dziedzic, Jacek Wojtach, and Daria Górka of MDDP. On September 28 2023, the Polish Ministry of Finance published the long-awaited draft of official guidelines on withholding tax (the Draft). The Draft relates to a…
The first-ever scent trademark has been registered in the European Union. Moreover, as much as 79% of consumers prefer to buy products with “eco” trademarks. The appearance of the Apple store is registered as a trademark. A patent claim must be written in the form of a single sentence, and this rule applies worldwide… All…
Identifying the links between parties to a transaction is not only crucial, but also one of the first things a taxpayer should do before proceeding with transfer pricing documentation and reporting obligations. Given the high volatility and uncertainty of the tax laws, it is worthwhile to verify well in advance that for a given year…
Or rather, on the premise of beneficial ownership, since, despite the name of the project (‘clarifications on withholding tax collection’), their scope is limited to the aforementioned aspect. The deadline for comments is 10 October. The draft clarifications raise even more questions than the original one from June 2019. Lack of precision and confusion of…
Safe harbour is a mechanism to reduce documentation and transfer pricing reporting obligations provided that the taxpayer meets several statutory requirements. Once such conditions are met, the taxpayer is supposed to gain certainty as to the arm’s length nature of the price applied in the transaction carried out. However, is compliance with the conditions sufficient…
Group documentation is treated a bit lightly by taxpayers. After the hassle of preparing Local File with transfer pricing analyses and properly completing and submitting the TP-R form, many taxpayers would like to take a breather from transfer pricing obligations. However, we would like to remind you that for some taxpayers, group documentation is just…
In today’s dynamic business environment, organizations face constant challenges to remain efficient and competitive. In this context, one of the key aspects that often consumes a lot of time and resources is the preparation of various documents, such as financial records, reports, commercial offers, reports or tax documentation. The process of creating such documents requires…