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…

Does a gratuitous guarantee under Estonian CIT mean no transfer pricing obligations?

Corporate tax, INSIGHT, Transfer pricing, Trochę o CIT

Does a gratuitous guarantee granted to a taxpayer subject to Estonian CIT by a related entity give rise to a transfer pricing documentation obligation? According to DKIS [1] – yes – if the value of the guarantee exceeds the threshold of PLN 10 million, the taxpayer will be required to prepare transfer pricing documentation.  …

General partnership and transfer pricing in 2025 – Local file documentation, CIT-15J and TP obligations

General partnership and transfer pricing in 2025 – Local file documentation, CIT-15J and TP obligations

Transfer pricing

The arm’s length principle applies to all entities conducting transactions with related parties and to all transactions – regardless their value. Even if a transaction does not exceed the documentation thresholds and does not trigger the obligation to prepare local transfer pricing documentation, it is not exempt from complying with the arm’s length principle. Transfer…

The new Omnibus Package and ESG taxonomy

Green Taxation, INSIGHT, Trochę o zielonych podatkach

Recent discussions have focused on the EU institutions’ evolving stance on ESG (Environmental, Social and Governance) reporting. A central element of these changes is the so-called Omnibus Package, which introduces substantial amendments to both existing and forthcoming regulations—particularly the Corporate Sustainability Reporting Directive (CSRD) and the EU Taxonomy-related implementing measures. A new direction from the…

Intra-group settlements under the scrutiny of the CJEU – key issues in transfer pricing and VAT

Intra-group settlements under the scrutiny of the CJEU – key issues in transfer pricing and VAT

Transfer pricing, Trochę o VAT

The issue of intra-group transactions in the context of value-added tax (VAT) is increasingly attracting the attention of the Court of Justice of the European Union (CJEU). Recent cases underscore the importance of delineating the boundaries between direct tax (CIT) and indirect tax (VAT) regulations, as well as the significant practical implications that transfer pricing…