Does a free of charge surety granted to a taxpayer subject to Estonian CIT give rise to a tax obligation to recognise income as hidden profits or revenue from free of charge benefits? The conclusions of the latest individual tax ruling[1] indicate that it does not. Hidden profit or income from a free of…
Can the payment of remuneration for the redemption of shares, financed from profits earned before the implementation of Estonian CIT, result in lump-sum taxation of company income? Although it may appear that profits once subject to taxation should not be subject to further taxation, tax authorities’ practices demonstrate otherwise. For the tax authority, it…
Recently issued individual interpretations indicate that tax authorities have inconsistent positions on the classification of lease or rental costs from related entities as so-called hidden profits. While the regulations remain consistent, the authorities’ positions are subject to variation depending on the specifics of each case. The following three approaches demonstrate the various perspectives of the…
The real estate tax regulations in force from 2025 have affected the industrial sector. In this and a series of subsequent articles, we will highlight the issues most frequently identified by MDDP experts as affecting industry. Are industrial installations considered buildings? The change in the definition of a structure and a building means that…
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…
The extended deadline for submitting real estate tax returns expired on 31 March 2025. Below, we highlight the issues for each type of commercial property that were most frequently identified by MDDP experts. How have the new regulations affected the taxation of shopping centres? No longer excluded from taxation are the so-called small architectural…
Many entrepreneurs in Poland would like to have lower tax liabilities. It’s worth taking a closer look at the opportunities introduced by the legislator.One such mechanism that can help reduce CIT tax is hypothetical interest on equity capital. What is hypothetical interest? Hypothetical interest is the amount a company would potentially pay as interest if…
The draft amendment to the Tax Ordinance Act and certain other acts runs to 52 pages, and more than half of its contents are changes to the Mandatory Disclosure Rules (MDR) provisions. The proposed changes to the MDR provisions are comprehensive and, in some aspects, revolutionary. Several of the proposed changes are structural in nature…
The estonian CIT, or lump-sum tax on company income, is a form of taxation that allows the postponement of tax payment until the actual distribution of profits to an individual – a shareholder. A key element in the initial phase of applying this taxation model is the calculation of the so-called preliminary adjustment. The essence…
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…