On 8 November 2022[1], the Court of Justice of the European Union (‘the CJEU’) annulled the decision of the European Commission and the judgment of the EU Court, which recognized the individual ruling issued by the authorities in Luxembourg as providing a ‘selective advantage’ to Fiat Chrysler Finance Europe, which – according to the Commission…
Autumn has come and it has been followed by another changes in tax regulations, including the flat-rate income tax, or so-called withholding tax. Background to the changes The current version of the withholding tax regulations came into force on 1 January 2022. However, the fact that the legislator plans to amend the withholding tax rules…
Transactions involving intangible assets are among related-party transactions causing the greatest difficulties for taxpayers when meeting their transfer pricing obligations. Taxpayers often find it challenging to prepare the valuation of intangible assets itself. They also need to remember that in the case of transfer pricing it is also necessary to adopt market assumptions for transactions…
Some taxpayers currently compiling Local Files and TP-R forms for 2021 will not complete their struggle with transfer pricing on 31 December 31 (if their tax year matches the calendar year). They will face additional obligations related to Master File for 2021. What is Master File? The Master File is (shortly) an integral part of…
The most important change concerning the minimum tax is the exemption of taxpayers from this tax in 2022 and 2023. For taxpayers whose fiscal year is different from the calendar year and starts before 1 January 2024 and ends after 31 December 2023, the exemption will apply until the end of that fiscal year. The…
The reform of Estonian CIT (sometimes called as “lump sum taxation”) under the Polish Deal, which began in 2022, allowed for a significant expansion of access to this form of taxation, e.g. by expanding the catalogue of entities eligible to apply Estonian CIT, reducing the flat rate on income, and abolishing the revenue limit. Thanks…
There is less than a month left to meet the transfer pricing reporting deadlines. One of the obligations is to file to the Polish tax office a statement on transfer pricing documentation and on the arm’s length nature of the transaction. The statement shall be signed by members of the company’s management board. For most…
Taxpayers actively promoting their own products may, starting from 2022, make more deductions from their tax base. Tax credit for enhanced product sales is a kind of closing bracket for other deductions introduced with regard to taxpayers’ manufacture of their products. This time, the legislator touches upon the final element of selling one’s own products,…
Starting from 1 January 2022, two tax credits closely linked to the Initial Public Offering (IPO), or, in a nutshell, the stock market debut of a company, have been introduced into income tax laws. The first of the two IPO tax credits is aimed at corporate income tax payers deciding to conduct such an IPO.…
The deadline for filing TPR for 2021 with the Head of KAS is looming – 31 December 2022! Do not work on the TPR at the very last minute. Instead, complete it as early as possible. Failure to comply with this obligation can be costly. The prospect of penalties Completing the form hastily may result…