Disposal of an organised part of an enterprise – what does it involve, what are the tax risks and how can they be secured?

Disposal of an organised part of an enterprise – what does it involve, what are the tax risks and how can they be secured?

Corporate tax, Trochę o CIT, Trochę o VAT, VAT

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.…

Master File (group transfer pricing documentation) – what is it and who is required to prepare it?

Master File (group transfer pricing documentation) – what is it and who is required to prepare it?

Transfer pricing

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 –…

Repeated services provided by a partner in Estonian CIT

Corporate tax, Trochę o CIT

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…

Dividends and interest from abroad – another favourable ruling by the Supreme Administrative Court

INSIGHT, Personal Taxes

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…

CBAM: what will change? Overview of upcoming changes for importers

Green Taxation, INSIGHT, Trochę o zielonych podatkach

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…

Intra-group settlements under scrutiny by the CJEU - what does the Weatherford ruling mean for intra-group service acquisitions?

Intra-group settlements under scrutiny by the CJEU – what does the Weatherford ruling mean for intra-group service acquisitions?

Transfer pricing, Trochę o VAT

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…

Crypto transaction reporting from 2026 – what should crypto-asset service providers know about DAC8?

Tech TAX

Starting in 2026, new regulations on the automatic exchange of information regarding crypto-asset transactions will come into force across the European Union. These rules will introduce mandatory reporting obligations for a broad range of entities operating in the crypto sector – including platform operators, token issuers, wallet providers, crypto exchanges, and other companies facilitating the…