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…
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…
GloBE: Latest proposals from the Ministry of Finance on the shape of the R&D tax relief On 9 April, a meeting was held with representatives of the Income Tax Department of the Ministry of Finance. The purpose of the meeting was to discuss two scenarios (A and B) for changes to the regulations on the…
“Stop-the-Clock”: Postponement of CSRD and CSDDD implementation timelines On 3 April 2025, the European Parliament voted in favour of postponing the implementation timelines of the CSRD (Corporate Sustainability Reporting Directive) and the CSDDD (Corporate Sustainability Due Diligence Directive). This decision follows the adoption of the “Stop-the-Clock” mechanism, which forms part of the Omnibus package presented…
A marriage may be regarded as a VAT taxpayer! – Groundbreaking CJEU ruling in Case C-213/24, Grzera On 3rd April 2025, the CJEU delivered a highly significant judgment in the Polish Case C-213/24, Grzera. The ruling concerns, firstly, whether a seller can be considered a VAT taxpayer if they order the preparation of the transaction…