On 16 June 2025, the Supreme Administrative Court (NSA) declined to adopt a resolution in a case of significant importance to the practice of VAT refunds. The central legal issue concerned whether administrative courts, when reviewing an order to extend the deadline for a VAT refund, may also examine earlier, non-appealed orders issued in the…
On 3 July 2025, the CJEU once again spoke on the VAT treatment of intra-group transactions – this time in judgment C-808/23 Högkullen. Factual state Högkullen AB, the Swedish parent company in the real estate management group, operated solely in the area of managing subsidiaries and provided them with paid management, financial, personnel, etc. services.…
The resolution of the Supreme Administrative Court (NSA) of 16 June 2025 (case no. III FPS 1/25) settles a dispute regarding the delivery of an enforceability warrant issued under Article 155b § 1 of the Act on Enforcement Proceedings in Administration. The NSA held that such a warrant must be served on the authorized representative…
In the first article of our TP & VAT series (link: https://www.mddp.pl/intra-group-settlements-under-the-scrutiny-of-the-cjeu/ ), we outlined the general background to recent rulings by the Court of Justice of the European Union (CJEU) in this area. Today, we delve deeper into the topic by analysing the Weatherford judgment (Case C-527/23), which carries significant implications for the interpretation…
KSeF – the Final Stage of the Legislative Process On 17 June 2025, the Council of Ministers adopted the draft act implementing the mandatory National e-Invoicing System (KSeF), marking the final stage of the legislative process. It appears that no major amendments are expected during parliamentary proceedings, and the version of the KSeF proposed by…
KSeF 2.0 – status at the beginning of June 2025 The package of regulations setting out the final shape of the KSeF published on Friday 30 May (formally a draft dated 23 May 2025), is expected to reach the deliberations of the SKRM on the day of writing this article (5 June). Moving to the…
The issue of intra-group transactions in the context of value-added tax (VAT) is increasingly attracting the attention of the Court of Justice of the European Union (CJEU). Recent cases underscore the importance of delineating the boundaries between direct tax (CIT) and indirect tax (VAT) regulations, as well as the significant practical implications that transfer pricing…
The Offline24 mode – as explicitly described by the Ministry of Finance – is considered the most significant enhancement introduced to support entrepreneurs in implementing the National e-Invoicing System (KSeF). But is it truly a facilitation, or rather a trap resulting from not fully thought-out legislative solutions proposed in the April draft of the KSeF…
Modern companies operating in international markets face the challenge of aligning customs and transfer pricing policies. A lack of consistency between these areas can lead to significant tax, operational and financial risks. For this reason, close cooperation between customs and transfer pricing departments is essential – only through collaboration can risks be effectively managed, and…
With the launch of the first deposit return systems in October 2025, new rules will come into force for beverage containers included in the system and marked with the “DEPOSIT” on a label. However, many beverage containers will remain on the market—either temporarily or permanently—that are not included in the deposit system. This will significantly…