The tax authorities’ approach to reporting indirect ownership of real estate is changing again
Changes in the tax authorities’ approach to reporting indirect property ownership by real estate companies – evolving asset qualification rules.
Exemption of dividends from withholding tax without the requirement of beneficial ownership status – significance of the Head of the National Tax Information Service’s ruling
The condition of beneficial ownership has remained one of the key issues in withholding tax for many years, particularly in the context of applying exemptions provided for in the CIT Act. The legislator explicitly made the exemption from withholding tax on royalties and interest conditional upon beneficial ownership. In practice, however, tax authorities tend to…
“Total working time” in R&D tax relief – how should it understood?
Eligible costs under the research and development (R&D) tax relief include, among others, expenses incurred on the remuneration of employees performing R&D activities. These expenses may be deducted to the extent that the time devoted to R&D activities remains in proportion to the employee’s total working time in a given month. Moreover, the concept of…
First general interpretation of real estate tax in years
On December 1, 2025, the Minister of Finance and Economy issued a general interpretation[1] regarding real estate tax, which concerns the understanding of the concept of land, buildings, and structures related to business activity. The meaning of this phrase is decisive in determining which tax rate to apply. It is important to be aware that…
Master File and Withholding Tax (WHT). What does a Polish company in an international group need to know?
How does the Master File impact withholding tax (WHT) in Poland? Review the key risks, obligations, and actions that a Polish company within an international group should consider.
Choosing the Estonian CIT and the delayed signing of the financial statement – Ministry of Finance softens its approach
Change of taxation form to Estonian CIT A company may opt for Estonian CIT taxation during the tax year, provided that it closes its accounting books and prepares financial statements in accordance with the Accounting Act on the last day of the month preceding the first month of lump-sum taxation. In practice, the tax authorities…
Tax after leaving the Estonian CIT – how does the lump sum tax on company income work? New interpretation by the Director of the National Tax Information Service 2025
The departure of the Estonian CIT has led to a number of concerns being raised among entrepreneurs. Following the termination of the lump-sum tax on corporate income, what is the subsequent course of action for the tax? When does the tax obligation arise and how can costly mistakes be avoided? The answers are provided by…
WHT explanations – have holding companies finally been understood in terms of withholding tax?
WHT explanations – have holding companies gained understanding in withholding tax? What is the opinion of MDDP experts?
Estonian CIT and bond purchases – hidden risk of losing the right to a lump sum regime
Estonian CIT conditions One of the conditions of Estonian CIT is the appropriate structure of the company’s revenues. Passive income may not exceed 50% of total income. Passive income includes, in particular, income from receivables, interest, sureties, guarantees, copyrights, industrial property rights, as well as the sale and exercise of rights arising from financial instruments.…
Hidden gains in the draft amendment for 2026 – what may change in Estonian CIT?
The draft amendment to the income tax laws of September 16, 2025, provides for changes in the regulations concerning the lump sum tax on company income. The recent amendment to the definition of “hidden profits” has generated significant controversy, as it effectively determines which benefits between a company and its shareholders are subject to additional…