Estonian CIT and transfer pricing

Estonian CIT is an attractive form of taxation that can bring tangible tax benefits to companies. We discussed its advantages in more detail in our previous article: https://www.mddp.pl/zamkniecie-roku-dobry-czas-na-przejscie-na-cit-estonski/ In order to benefit from estonian CIT, taxpayers must meet certain conditions and operate in accordance with the principles of lump-sum taxation of corporate income. One of…

Company established through conversion of sole proprietorship is a taxpayer starting business

A capital company formed by the conversion of a sole proprietorship is considered as a taxpayer starting a business. On March 11, 2025, the Supreme Administrative Court issued a ruling (referenceII FSK 1412/24) that may significantly impact taxpayers arising from the transformation of sole proprietorships into limited liability companies or joint-stock companies. The ruling confirmed…

Withholding tax and the concept of industrial equipment – unfavorable position of the SAC

Both the provisions of the Corporate Income Tax (CIT) Act and the provisions of various double taxation treaties provide for the obligation to withhold tax on payments made to non-residents for the use of so-called “industrial equipment.” In principle, non-residents earning income in Poland from the use or right to use industrial equipment, including means…