The sports industry is constantly growing year on year, and its development is closely linked to the increasing level of sponsorship. Sponsors are a kind of stimulus for the development and expansion of Polish sports clubs, both in the domestic and international sports world. However, sponsorship payments also entail a number of income tax consequences…
On 9 July 2025, the Minister of Finance published the long-awaited tax explanatory notes regarding so-called beneficial owner clause for withholding tax purposes (hereinafter: WHT Explanatory Notes). Their publication is of significant importance for withholding tax remitters and taxpayers who, since 2022, have been and continue to be particularly exposed to increased controls and proceedings…
The expansion relief (under Article 18eb of the CIT Act) is an attractive incentive for entrepreneurs who want to develop sales of their products. One of the conditions for applying the relief is an increase in revenue from the sale of own products, including products not previously offered by the entrepreneur. Many doubts have arisen…
The Director of the National Tax Information Service (KIS) has once again emphasised that remuneration paid to a company’s proxy, who is also a related entity, is taxable as income from hidden profits. For instance, on 17 April 2025, the authority issued an individual interpretation (ref. no. 0111-KDIB1-2.4010.135.2025.1.MK), in which it was stated that the…
Many believed that the long-standing disputes over the correct property tax rate for residential units owned by businesses would be resolved following the resolution issued by the Supreme Administrative Court (NSA) in a panel of seven judges[1]. The Court clearly stated that when a residential unit is used to meet the housing needs of a…
The innovative employees tax relief, regulated in Article 18db of the CIT Act, was introduced into the Polish legal system as a tool to support entrepreneurs conducting research and development (R&D) activities who were unable to take full advantage of the R&D relief (Article 18d of the CIT Act) due to losses or insufficient income.…
The Polish Holding Company (PHC) is an institution that was supposed to encourage the establishment of holding structures in Poland by offering CIT exemption for dividends and income from the sale of shares in subsidiaries. The planned amendment to the regulations may make it easier to take advantage of this solution. The Ministry of Finance…
The introduction of a tax exemption known as the Polish Holding Company (PHC) into the Corporate Income Tax Act was intended to increase Poland’s attractiveness as a location for investment structures and to create a competitive tax environment. It is difficult not to notice that on the tax map of Europe alone, Poland has long…
A fundamental requirement for Estonian CIT is that the majority of revenue must be derived from operating activities. In practice, this means that less than half of the company’s total gross revenue may come from so-called passive sources. In the list compiled by the legislator, the following items are included: income from the disposal and…
Organised part of an enterprise Tax regulations define an organised part of an enterprise [hereinafter: OPE] as a set of assets – tangible and intangible, including liabilities – organisationally and financially separated within an existing enterprise, intended to perform specific business tasks, which could also constitute an independent enterprise performing these tasks on its own.…