Polish tax authorities’ approach to TP adjustments: hope for change? While conducting intragroup transactions, the application of transfer pricing adjustments is a common practice globally, especially among multinational groups. The guidelines published by OECD stress their main purpose, which is to appropriately remunerate individual entities based on their activities and the risks they incur, as…
Recent developments in Polish tax exemption for foreign investment funds Piotr Paśko and Tomasz Janik of MDDP say that while application of the tax exemption has historically been challenging, foreign investment vehicles stand to benefit as a more favourable environment appears to be emerging. The Polish Corporate Income Tax Act provides for an…
First draft of GloBE implementation act submitted in Poland Council Directive (EU) 2022/2523 of 15 December 2022 seeks to ensure a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union. The Polish Ministry of Finance has published for consultation a draft of an act implementing into Polish…
Greater tax certainty for investors in Poland Poland has been an attractive place for foreign direct investment for years. It has become one of the main locations for outsourcing financial functions for corporations around the world. And its location between the East and the West, in a complicated geopolitical situation and supply chain disruptions, makes…
Brexit has made us busy. Why? While it may have been sold by some as a way of cutting red tape, Britain’s exit from the single market has presented numerous new rules for exports and imports. This has led to an increased demand for lawyers and customs agents to help confused businesses navigate…
Tax aspects of redevelopment in the real-estate industry A lack of investment plots in prime locations means that developers are increasingly interested in purchasing developed properties such as old office buildings, commercial or industrial facilities either to demolish or modernise it. Such redevelopment has recently become a trend, especially among residential developers, as…
What Poland thinks of Britain’s post-Brexit border checks The volume of meat imports has increased since 2021 as Polish companies saw that Britain’s slaughterhouses were struggling to recruit staff in the wake of Brexit. Supermarkets were receptive to the pitch that Polish producers could source quality meat at more competitive prices than available from…
Applying the parent–subsidiary exemption in Poland is becoming more difficult Monika Dziedzic and Łukasz Kumkowski consider the dividend taxation exemption for payments made by Polish companies and explain the fulfilment of the beneficial ownership requirement by foreign holding companies To apply a parent–subsidiary exemption, Polish tax authorities require that recipients of dividend payments (paid by…
Guide to Poland’s filing obligations for real estate companies and their shareholders Polish real estate companies and their shareholders are required to submit the following information by April 2 2024: Real estate companies are mandated to disclose information about entities that directly or indirectly hold shares or similar rights in that real estate company,…
Guide to the initial phase of the CBAM With the first reports under the carbon border adjustment mechanism due at the end of January 2024, Agnieszka Kisielewska of MDDP explains the criteria for its application and the reporting obligations for affected importers. The carbon border adjustment mechanism (CBAM) starts with its transitional phase from October…