New European Commission initiative At the beginning of July 2025, the European Commission published recommendations on the design of tax incentives to support investment in clean technologies and industrial decarbonisation. This document is part of the Clean Industrial Deal, an EU strategy to build a competitive, low-carbon industrial base in line with the EU’s climate…
A fundamental requirement for Estonian CIT is that the majority of revenue must be derived from operating activities. In practice, this means that less than half of the company’s total gross revenue may come from so-called passive sources. In the list compiled by the legislator, the following items are included: income from the disposal and…
Organised part of an enterprise Tax regulations define an organised part of an enterprise [hereinafter: OPE] as a set of assets – tangible and intangible, including liabilities – organisationally and financially separated within an existing enterprise, intended to perform specific business tasks, which could also constitute an independent enterprise performing these tasks on its own.…
Deadlines for transfer pricing obligations in Poland – TPR form and the Local File for 2024 – are approaching fast. Find out how much time is really left, which mistakes to avoid, and why acting now – before the end of summer – is your best option. Only 60 days after the summer break That’s…
For many taxpayers, transfer pricing (TP) compliance forms a crucial part of their annual tax closing procedures. The period from October to December is typically intensive –preparing the Local File and submitting the TPR-C form requires precision and coordination across multiple departments. Alongside local documentation, the Master File – the group-level transfer pricing documentation –…
The tax authorities have changed their position on the so-called repeated non-monetary services provided by partners in limited liability companies with Estonian CIT, based on Article 176 of the Commercial Companies Code. Repeated benefits result from the shareholders’ obligation, specified in the articles of association, to perform activities of a remunerated and repetitive nature for…
On 24 June 2025, the Supreme Administrative Court (SAC) once again questioned the tax authorities’ approach to the taxation of foreign dividends and interest. The case concerned the possibility of deducting tax paid abroad from the Polish flat-rate tax (19%). For years, tax authorities have argued that such a deduction is limited to the rate…
On 1 January 2026, the transitional period for the CBAM (Carbon Border Adjustment Mechanism) will come to an end. The entry into force of the full CBAM regulations will introduce new administrative and reporting obligations for importers of goods from outside the EU. At the same time, the European Commission has announced significant simplifications for…
In the first article of our TP & VAT series (link: https://www.mddp.pl/intra-group-settlements-under-the-scrutiny-of-the-cjeu/ ), we outlined the general background to recent rulings by the Court of Justice of the European Union (CJEU) in this area. Today, we delve deeper into the topic by analysing the Weatherford judgment (Case C-527/23), which carries significant implications for the interpretation…
KSeF – the Final Stage of the Legislative Process On 17 June 2025, the Council of Ministers adopted the draft act implementing the mandatory National e-Invoicing System (KSeF), marking the final stage of the legislative process. It appears that no major amendments are expected during parliamentary proceedings, and the version of the KSeF proposed by…