Withholding Tax (WHT) and Transfer Pricing – how do tax authorities use the Master File? Practical and case law insights

Withholding Tax (WHT) and Transfer Pricing – how do tax authorities use the Master File? Practical and case law insights

Transfer pricing documentation within multinational capital groups has become an invaluable tool not only in the context of transfer pricing verification, but also in relation to other taxes, including withholding tax (WHT). In Poland, tax authorities are increasingly referring to group documentation, namely the Master File, during WHT audits.

Purchase of a production line and the robotisation tax relief

Purchase of a production line and the robotisation tax relief

One of the key categories of eligible costs under the robotisation tax relief includes expenses incurred for the acquisition of brand-new industrial robots as well as machinery and peripheral equipment functionally related to them. This particularly covers devices ensuring ergonomics and workplace safety in environments where human–robot interaction occurs, as well as solutions enabling remote…

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

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…

Choosing the Estonian CIT and the delayed signing of the financial statement – Ministry of Finance softens its approach

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…