Avoiding a ‘delayed time bomb’: how master file documentation impacts Polish WHT Poland has adopted a three-tiered transfer pricing documentation structure in line with OECD guidelines. This includes: The master file, which contains standardised information relevant for all members of the multinational enterprise (MNE) group; The local file, which refers to material transactions of the…
Poland tightens transfer pricing oversight: what’s coming next? In recent months, transfer pricing has become a key focus for tax authorities in Poland. Although the number of audits has declined, the focus is sharper. The rising amounts of adjusted taxable income and the creation of new structures within the Ministry of Finance and the National…
Report highlights the changing realities of tax controls in Poland Jakub Warnieło and Aleksandra Bulaszewska outline the key takeaways from a report on Polish tax trends, covering tax inspections, verification activities, tax proceedings, and the business viewpoint. A report published in June 2025 by MDDP in cooperation with the Polish Lewiatan Confederation provides a…
Cryptoassets in Poland: tax traps, reporting duties, and risks. Tax authorities intensify scrutiny to ensure compliance and tackle non-compliance.
Poland’s digital tax revolution is coming: JPK CIT and e-invoicing explained Rafał Kran and Janina Fornalik of MDDP analyse the introduction of the JPK CIT and e-invoicing, outlining how companies should prepare for sweeping digital reporting and compliance changes Poland has entered the next phase of its digital revolution in tax, bringing new electronic…
Poland’s new explanatory guidelines ‘create tension’ with EU over beneficial ownership The Polish Ministry of Finance published explanatory guidelines (hereinafter: the Guidelines) on the application of the beneficial owner (BO) clause in Withholding Tax (WHT). These document has been long-awaited as it addresses ambiguities faced by taxpayers. Although it resolves a few of long-standing problems,…
Poland proposes overhauling foreign fund tax exemption to align with EU law The recently published amendment to the CIT act constitutes an answer to the taxpayers’ doubts concerning rules on the tax exemption for foreign investment funds. The need for new legislation stemmed from two key Court of Justice of the European Union judgments, which…
Clarified beneficial ownership rules and introduction of overseas investment fund exemptions Ministry of Finance has recently published long-awaited explanatory notes on Withholding Tax (WHT), addressing long-standing ambiguities, which taxpayers had to face. These notes concern particularly the definition of beneficial owner, which lies at the heart of WHT regime and constitutes the condition for applying…
Poland’s Estonian CIT: an increasingly attractive option for domestic and foreign investors Poland’s Estonian-style corporate income tax (CIT) regime has become an increasingly popular choice among taxpayers. Introduced in 2021 and significantly liberalised in 2022, the system has already been adopted by over 20,000 companies operating in Poland. A structural shift in corporate taxation…
Tax challenges in the construction sector The construction industry in Poland is facing many challenges – ranging from labor shortages, increasing material costs, through energy efficiency requirements, to tax implications. Such operational and financial hurdles create an increasingly demanding environment, which companies must navigate. One of the major issues present in the construction industry are…