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…
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…
Lump-sum tax on corporate income [Estonian CIT], as a very attractive form of taxation for individuals, is steadily gaining popularity. This is evidenced by the fact that the number of taxpayers subject to Estonian CIT is increasing every year. One interesting aspect of Estonian CIT concerns dividends in kind. When is tax payable under Estonian…
Many taxpayers living and working abroad ask themselves: does the mere fact that my family resides in Poland mean that I am still considered a Polish tax resident? The answer is not straightforward. The mere fact that a spouse or children live in Poland does not determine that the taxpayer’s centre of personal interests is…
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. …
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…
Family foundations have been part of the Polish legal system for over two years and have naturally become a popular tool for succession planning. As they gain traction, questions have arisen regarding the permissibility of accumulating and disposing of digital assets by family foundations, especially in light of their tax-advantaged status. In its tax ruling…
Does a free of charge surety granted to a taxpayer subject to Estonian CIT give rise to a tax obligation to recognise income as hidden profits or revenue from free of charge benefits? The conclusions of the latest individual tax ruling[1] indicate that it does not. Hidden profit or income from a free of…