A few words about the CJEU ruling on November 21st, 2024, ref. C-624/23, SEM Remont. Case overview The ruling was issued in connection with a transaction in which, in August 2020, the Bulgarian company SEM Remont contracted the Russian company Gidrostroy – Russia to carry out dredging...

On January 1, 2025, new real estate tax regulations come into effect On November 29, 2024, the Law of November 19, 2024, amending the rules for real estate taxation (PON) was published in the Journal of Laws. The changes particularly concern the scope of taxable property. Other taxation...

Despite the wording of  the provision on the condition of ‘being subject to tax’ sounds the same for dividends, interest and royalties, the MoF followed up its ruling on dividends by issuing an general tax  ruling on this condition for interest and royalties (DD9.8202.2.2024). What...

In recent days, the Ministry of Finance has published two general rulings relating to some of the conditions for the exemption from withholding tax of dividend and interest payments. These rulings are important, but are they groundbreaking? How will the existing practice of the authorities...

How does the SME directive change settlements with contractors? The Act implementing the so-called SME Directive has been signed by the President of Poland and published in the Journal of Laws. Currently, a secondary regulation and amendments to the VAT-R form are under consideration....

MDDP advised Ghelamco on the sale of Warsaw Unit Experts from MDDP Michalik Dłuska Dziedzic and Partners advised Ghelamco on the sale of Warsaw Unit to the Eastnine fund. The transaction had a value of €280 million and was considered the largest in the European office market in 2024. The...

In its judgment of 14 November 2024 (Case C-613/23), the Court of Justice of the EU held that national legislation allowing a company’s tax arrears to be passed on to the company’s manager where the manager fails to comply with the company’s obligation to give notice...

Cash pooling is a widely used solution among capital groups. It streamlines the management of funds across multiple entities and enhances liquidity control. This approach leads to cost savings and more efficient financial management within the group. Cash pool arrangement –...

With the growing popularity of international expansion, more and more Polish entrepreneurs are deciding to establish companies outside of the country. Such decisions pose a range of tax-related questions for taxpayers. One of the key issues is whether income earned from the activities...

An important for the property development sector and interesting from the VAT point of view ruling was issued by the CJEU on November 7th, 2024. The case C-594/23 (Lomoco Development ApS and others) was between the Danish Ministry of Taxation and several property development companies....

GloBE Act signed by the President of Poland On 15 November this year the President of Poland signed the Act of 6 November 2024 on the top-up tax of constituent entities of multinational and domestic groups! The Act will soon be promulgated in the Polish Journal of Laws.   The Act...

Poland’s minimum income tax[1] may be particularly burdensome for the tobacco industry and international aircraft charter companies. What does this mean for entrepreneurs? The tobacco industry will not pay the minimum income tax For calculating the loss or level of profitability,...

Cash PIT from January 2025 Starting January 1, 2025, certain entrepreneurs conducting sole proprietorships will be able to opt for cash PIT method. What is cash PIT method? Currently, entrepreneurs recognize revenue on an accrual basis, regardless of when payments are settled. This...

The definition of ‘real estate company’ and the doubts related to it According to the regulations, a real estate company is an entity, other than a natural person, obliged to prepare a balance sheet on the basis of accounting regulations, in which at least 50% of the balance sheet...

GloBE Act in the final legislative stage The Polish Parliament enacted the Act of 6 November 2024 on the top-up tax of constituent entities of multinational and domestic groups. The Act is awaiting the signature of the President of Poland. The Act of 6 November 2024 on the top-up...