On 9 July 2025, the Minister of Finance published the long-awaited tax explanatory notes regarding so-called beneficial owner clause for withholding tax purposes (hereinafter: WHT Explanatory Notes). Their publication is of significant importance for withholding tax remitters and taxpayers who, since 2022, have been and continue to be particularly exposed to increased controls and proceedings…
If you bought or sold cryptocurrencies (or, to use the formal term, virtual currencies) during the tax year, you will need to report either the income you earned or the costs you incurred in your annual PIT-38 return. The deadline for filing is April 30 of the following year. This requirement also applies if you…
The expansion relief (under Article 18eb of the CIT Act) is an attractive incentive for entrepreneurs who want to develop sales of their products. One of the conditions for applying the relief is an increase in revenue from the sale of own products, including products not previously offered by the entrepreneur. Many doubts have arisen…
Many believed that the long-standing disputes over the correct property tax rate for residential units owned by businesses would be resolved following the resolution issued by the Supreme Administrative Court (NSA) in a panel of seven judges[1]. The Court clearly stated that when a residential unit is used to meet the housing needs of a…
The innovative employees tax relief, regulated in Article 18db of the CIT Act, was introduced into the Polish legal system as a tool to support entrepreneurs conducting research and development (R&D) activities who were unable to take full advantage of the R&D relief (Article 18d of the CIT Act) due to losses or insufficient income.…
In recent months, the topic of sustainability and related reporting obligations has remained one of the most pressing challenges for thousands of companies in Poland. This is largely due to the EU’s CSRD directive as well as the new, more demanding ESG reporting standards in the form of the ESRS. Omnibus – Simplification, not exemption…
The Supreme Administrative Court’s ruling of 15 May 2025 (ref. II FSK 163/25) provides clarity on one of the challenging and ambiguous issues concerning Estonian CIT. This refers to the condition of maintaining an appropriate level of employment for a minimum of 300 days in a tax year, as outlined in Article 28j(1)(3)(a) of the…
The Polish Holding Company (PHC) is an institution that was supposed to encourage the establishment of holding structures in Poland by offering CIT exemption for dividends and income from the sale of shares in subsidiaries. The planned amendment to the regulations may make it easier to take advantage of this solution. The Ministry of Finance…
Transfer pricing analysis forms the backbone of the Local File and the TPR (Transfer Pricing Report) form. Find out how to avoid income reassessments and prepare an analysis robust enough to pass a customs and tax audit. Introduction At first glance, everything appears to be in order. The company’s results fall within the range. Documentation…
The introduction of a tax exemption known as the Polish Holding Company (PHC) into the Corporate Income Tax Act was intended to increase Poland’s attractiveness as a location for investment structures and to create a competitive tax environment. It is difficult not to notice that on the tax map of Europe alone, Poland has long…