Simplified mergers are now clearly neutral for CIT purposes Amendment to the CIT Act within the framework of Energy Law changes On August 5, 2025, the Act amending the Energy Law and certain other acts clarified the Corporate Income Tax (CIT) regulations regarding mergers conducted under Article 515¹ of the Polish Commercial Companies Code. This…
The e-Invoicing Act (“KSeF 2.0”) published in the Journal of Laws The Act of August 5, 2025, amending the VAT Act and the so-called Act on the National e- Invoicing System (KSeF), introducing mandatory KSeF, was published on September 1, 2025, in the Journal of Laws of the Republic of Poland (item 1203) and is available…
Transfer pricing back in the spotlight. New presidential initiative could mean more audits A change in the Presidential Palace often signals a shift in economic and tax policy. This time, alongside the widely publicised proposal to introduce tax relief for families raising at least two children, the draft bill contains a provision that could significantly…
Ministry of Finance announces changes in the taxation of family foundations from 2026 On 8 August 2025, representatives from the Ministry of Finance and the Ministry of Economy announced an increase in the taxation of family foundations. According to the Ministry’s declarations, the purpose of the proposed regulations is to limit the use of family…
GloBE – automatic exchange of information – first signatories of the multilateral agreement (GIR-MCAA) and other tools for handling GloBE. On 6 August 2024, a list of 14 signatories to the multilateral agreement on information exchange GloBE (GIR-MCAA, GloBE Information Return-Multilateral Competent Authority Agreement) was announced. The list includes several EU Member States (Austria, Belgium,…
Work on draft Unshell Directive on hold – member states prefer DAC6 changes The Unshell Directive (ATAD3) is about companies without significant activities. It was intended to set an EU standard for the minimum substance of companies to prevent tax avoidance. The DAC 6 in the other hand obliges different entities (e.g. tax advisers) including,…
WHT Explanatory Notes from 3rd July, 2025 on the application of the so-called beneficial owner clause for withholding tax purposes On July 9th; 2025 the long-awaited WHT Explanatory Notes regarding the application of the so-called beneficial owner clause for withholding tax purposes (hereinafter: the WHT Explanatory Notes) have been published. The key points are as…
Extension of tax exemption for foreign investment funds The Ministry of Finance has published a draft amendment to the Corporate Income Tax (CIT) Act, responding to key judgements of the Court of Justice of the European Union (CJEU). The proposed regulations aim to eliminate the inconsistencies of current Polish law with EU law, as highlighted…
Landmark CJEU ruling on railway sidings and, more broadly, state aid in the context of taxation On 29 April 2025, the Court of Justice of the European Union in Luxembourg issued a ruling favourable to taxpayers in case C-453/23 concerning the Mayor of Mielec. This is the first CJEU ruling on Polish property tax. The…
Management board liability – another important CJEU judgment On 30 April, the Court of Justice of the European Union (CJEU) issued a significant judgment concerning the Polish regulations governing joint and several liability of management board members for a company’s tax arrears (Case C-278/24 Genzyński). This judgment challenges the entire model for pursuing proceedings against…